Low-level const appears in the base type of compound types such as pointers or references. Note that pointer types, unlike most other types, can have both top-level and low-level const independently

int i = 0;
int *const p1 = &i; // we can't change the value of p1; const is top-level
const int ci = 42; // we cannot change ci; const is top-level
const int *p2 = &ci; // we can change p2; const is low-level
const int *const p3 = p2; // right-most const is top-level, left-most is not
const int &r = ci; // const in reference types is always low-level