there are a few things that set fleeting notes and reference notes apart
a fleeting note is taken when you think or want to remember something on the go and while these notes may refer to media you’ve engaged with. Because they are not taken in formal settings and are almost your thoughts, they are not considered reference notes.
on the other hand, reference notes are taken while you are actively engaging with the material you are consuming and citing some of it into your notes with reference notes, and unlike fleeting notes, reference notes are stored in zettelkasten to be used as references.