LLA and Cobol copybook library

I don't know anything about "Cobol copybook libraries", but...

My first question, is this a valid/acceptable use of LLA to manage
non-loadlibraries?

Assuming this is truly not a load library, then in a word, No.

LLA might manage the directory entries for you but LLA caching of members
is only done with respect to loading of modules (or program objects). If
that is not how the members of this library are used, then LLA is not
involved with tracking usage of the members.

VLF can cache any type of data but needs to have an exploiter giving it the
data. Here it sounds like nothing is giving VLF data to cache.

Peter Relson
z/OS Core Technology Design

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