大方廣佛華嚴經隨疏演義鈔 17.28

17.28

疏「三普賢品初無別發起」者，若不屬前，此品之初應合別有發起；既無發起，明是屬前。

Regarding the Commentary's statement, 'Third, at the beginning of the Samantabhadra Chapter there is no separate initiation': If it did not belong to the preceding, then at the beginning of this chapter there should separately be an initiation; since there is no initiation, it is clear that it belongs to the preceding.