Two years ago we weren't talking about whether it could be done. We were talking about whether David Whittaker, a professional video games musician composing hundreds of modules per year would have entered his music by hand using ASM in text form. Not saying it wasn't possible, but do you really think that was likely?
As for conforming to a module format;
1) it was most likely HIS format and HIS tools which he probably had the source for giving any flexibility he needed.
2) Most of his modules use the same replay routine which to me kinda hints that he didn't want this flexibility very often.
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