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A further thought while considering this idea...even notwithstanding the APF-library access issues associated with changing the ZPARM using SET SYSPARM RELOAD, the dynamic decrease of DSMAX presents an additional problem, in that the ZPARM setting would take effect immediately.
While this WOULD cause Db2 to start closing open datasets, it also creates a window where the subsystem is technically OVER the DSMAX limit, so if more datasets needed to be opened for a new process, they may get 00C20113 errors.
A dynamic INCREASE of DSMAX via COMMAND would likely work the same way as doing it through ZPARM. A DECREASE, however, would require Db2 to close datasets up to the 3% margin from the NEW value of DSMAX BEFORE enforcing the new limit, to avoid any outage or RESOURCE UNAVAILABLE condition.