I think you have some superfluous code there, Shane.
Your existing code could be written as this single line:
D ADS EUDS EXTNAME(FILE)
- the "U" in column 23 assumes a Data Area Data Structure and reads in the *DTAARA ADS at the start of the program - no need for DEFINE or IN.
The equivalent free format would look like:
Dcl-DS ADS EXTNAME('FILE') Dtaara(*Auto) End-DS;