I meant that the contents of the D_FILE on a new machine is empty. The address of the D_FILE is 32064 when starting ZX812 with a 48k RAMpack on EightyOne.
I've given up on this, to be honest, and have concluded it's simply not possible to code in basic on a ZX81 past 16k of code. Haven't abandoned the project. Have started it totally from scratch with the intention to fit a more limited version of it within 16k. Thanks for everyone's help, but unless someone can provide a snapshot of a ZX81 machine on EightyOne with code activated beyond 16k, I'm not going to pursue this as I'm spending more time trying to activate code beyond 16k than coding. Coding is my love and this is taking me away from that. I'm done trying.