Is the comma in a variable list a sequence point?

I believe behavior is well-defined because of 8[dcl.decl]/3

Each init-declarator in a declaration is analyzed separately as if it was in a declaration by itself.

Which is even additionally explained in a footnote as

A declaration with several declarators is usually equivalent to the corresponding sequence of declarations each with a single
declarator. That is

T D1, D2, ... Dn;

is usually equvalent to

T D1; T D2; ... T Dn;

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