In Kassouf v. Township of Scott, 584 Pa. 219, 883 A.2d 463 (2005), a land developer sought final approval of a subdivision plan. In several correspondences, the township engineer specifically enumerated the defects in the developer's subdivision plan. The township commissioners thereafter denied the developer's application for final approval. In a written determination, the commissioners' listed 16 reasons for denying the application. The developer appealed to the court of common pleas and asserted, among other things, he was entitled to a deemed approval of his application because the commissioners' letter did not satisfy the requirements of the Pennsylvania Municipalities Planning Code (MPC). The common pleas court affirmed on the basis the commissioners' denial letter sufficiently complied with the MPC where it incorporated by reference the township engineer's correspondences. The Court affirmed. On further appeal, the Supreme Court reversed. Finding no impediment to incorporation by reference, the Kassouf Court explained: The fact that there is no absolute impediment to incorporation by reference, however, does not mean that any and all references to supporting documentation will provide, as a substantive matter, an adequate articulation of the reasons for denial purposes of the MPC. In this regard, the supposed incorporation here is far less clear, and far less obviously adequate, than was the explicit incorporation by reference in Advantage Development, Inc. v. Board of Supervisors of Jackson Township, 743 A.2d 1008 (Pa. Cmwlth. 2000). In the case sub judice, the township commissioners' decision letter does not refer to a specific report, identifiable by title or date or subject matter. Nor do the words "incorporate by reference" appear in the letter, and the commissioners did not attach any particular report or letter which they were supposedly incorporating by reference. ... It may well be ... that the surrounding context indicates that the commissioners were referring exclusively or primarily to the township engineer's final letter ... especially given the commissioners' repeated references to that specific letter .... And perhaps it is so that, even without using the language "incorporate by reference," or attaching the incorporated document, the township commissioners' decision nevertheless intended to incorporate and rely upon the engineer's ... letter. However, we agree with the developer that the subdivision applicant should not be left to guess at whether the township was truly relying upon an external document in lieu of its own ... statement. Nor should the applicant be left to guess as to which of multiple documents is the one that would serve as the "incorporated" basis for the decision. 584 Pa. at 233-234, 883 A.2d at 472.