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lex.phases p3 says a bit much in that location.
Maybe it's better to move the normative provision "Each comment (5.4) is replaced by one u+0020 space character." here or into lex.pptoken, possibly as part of the "whitespace grammar" paper.
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I was reluctant to touch the phases of translation more than necessary in P3657, the whitespace grammar paper. However, if we prefer that direction I will updated the next revision of that paper and close this PR.