The exact possibilities for the content of a PARM in a JCL deck depend on an 
interaction between "JCL" and the data the parm represents, (as David W Noon 
was keen to impress in the other thread on this).

What happens for PARM-in-JCL need not happen for PARM-in-PARMDD. PARMDD did not 
exist previously, you have to change the JCL significantly to use it, PARMDD 
data contains no elements of JCL, nothing relating to JCL directly (unless you 
count the symbol-substitution and && compression) and "does some other 
stuff", stripping what it (it being the PARMDD processing) thinks is a line 
number.

Taking your original example and putting it in PARMDD would not work, because 
the program using the PARM data would not understand the extra information.

Taking Charles' example and removing the comments and putting it in PARMDD 
would not work, because some of the PARM formatting in that example is to allow 
for the presence of the comments (those apostrophes).

Taking any PARM which has required extra formatting because the data of the 
PARM conflicted with JCL's understanding of how a line is formed and putting it 
unchanged into PARMDD would not work, because those extra bits of formatting 
for the JCL are still there, and now part of the data, which the program using 
the PARM data will not understand.

PARM is data. You can "embed" a comment in the JCL, but it is embedded in the 
JCL, not the data (in your example the commas have a dual role, they are data, 
and the JCL-processor sees them as JCL).

PARM is data. Sometimes the data requires encapsulation so that the 
JCL-processor understands.

PARMDD is data. There is no requirement or capability for de-encapsulating JCL 
that in an original PARM existed only to enforce a distinction between the data 
and the JCL.

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