Foundation Document: Tonto National Monument, Arizona
NPS Arrowhead
Mission of the National Park Service
The National Park Service (NPS) preserves unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations. The National Park Service cooperates with partners to extend the benefits of natural and cultural resource conservation and outdoor recreation throughout this country and the world.
The NPS core values are a framework in which the National Park Service accomplishes its mission. They express the manner in which, both individually and collectively, the National Park Service pursues its mission.
The NPS core values are:
Shared stewardship: We share a commitment to resource stewardship with the global preservation community.
Excellence: We strive continually to learn and improve so that we may achieve the highest ideals of public service.
Integrity: We deal honestly and fairly with the public and one another.
Tradition: We are proud of it; we learn from it; we are not bound by it.
Respect: We embrace each other’s differences so that we may enrich the well-being of everyone.
The National Park Service is a bureau within the Department of the Interior. While numerous national park system units were created prior to 1916, it was not until August 25, 1916, that President Woodrow Wilson signed the National Park Service Organic Act formally establishing the National Park Service.
The national park system continues to grow and comprises more than 400 park units covering more than 84 million acres in every state, the District of Columbia, American Samoa, Guam, Puerto Rico, and the Virgin Islands. These units include, but are not limited to, national parks, monuments, battlefields, military parks, historical parks, historic sites, lakeshores, seashores, recreation areas, scenic rivers and trails, and the White House. The variety and diversity of park units throughout the nation require a strong commitment to resource stewardship and management to ensure both the protection and enjoyment of these resources for future generations.
The arrowhead was authorized as the official National Park Service emblem by the Secretary of the Interior on July 20, 1951. The sequoia tree and bison represent vegetation and wildlife, the mountains and water represent scenic and recreational values, and the arrowhead represents historical and archeological values.
Introduction
Every unit of the national park system will have a foundational document to provide basic guidance for planning and management decisions—a foundation for planning and management. The core components of a foundation document include a brief description of the park as well as the park’s purpose, significance, fundamental resources and values, and interpretive themes. The foundation document also includes special mandates and administrative commitments, an assessment of planning and data needs that identifies planning issues, planning products to be developed, and the associated studies and data required for park planning. Along with the core components, the assessment provides a focus for park planning activities and establishes a baseline from which planning documents are developed.
A primary benefit of developing a foundation document is the opportunity to integrate and coordinate all kinds and levels of planning from a single, shared understanding of what is most important about the park. The process of developing a foundation document begins with gathering and integrating information about the park. Next, this information is refined and focused to determine what the most important attributes of the park are. The process of preparing a foundation document aids park managers, staff, and the public in identifying and clearly stating in one document the essential information that is necessary for park management to consider when determining future planning efforts, outlining key planning issues, and protecting resources and values that are integral to park purpose and identity.
While not included in this document, a park atlas is also part of a foundation project. The atlas is a series of maps compiled from available geographic information system (GIS) data on natural and cultural resources, visitor use patterns, facilities, and other topics. It serves as a GIS-based support tool for planning and park operations. The atlas is published as a (hard copy) paper product and as geospatial data for use in a web mapping environment.
H. Clark
Part 1: Core Components
The core components of a foundation document include a brief description of the park, park purpose, significance statements, fundamental resources and values, and interpretive themes. These components are core because they typically do not change over time. Core components are expected to be used in future planning and management efforts.
Brief Description of the Park
Tonto National Monument was set aside in 1907 by President Theodore Roosevelt to preserve and protect critical archeological evidence of the prehistoric Salado culture of central Arizona’s Tonto Basin. Most notable are two large cliff dwellings constructed during the 14th century. The monument also protects the areas within the Tonto National Monument Archeological District along with the arid habitat of the northeastern edge of the Sonoran Desert.
The Tonto Basin extends for more than 300 square miles and supports a wide diversity of animals and plants. Both Tonto Creek and the Salt River provide year-round water as well as depositing rich soils along the valley floor. People have been drawn to this area for thousands of years, taking advantage of the abundance of food and materials. Permanent settlements started around AD 100–AD 600. Gradually, more people moved into the basin, bringing with them new ideas, technologies, and philosophies, resulting in changes to Tonto Basin’s cultural identity. By 1250, most of the prime land on the valley floor was occupied and new arrivals began settling in the higher elevations. By 1275, thousands of people lived in the Tonto Basin. Archeologists refer to this mixed-cultural phenomenon as the Salado culture.
In the 1300s, changes were occurring throughout the Tonto Basin. During the early years of the century the populations flourished and were relatively stable. Over time, however, a drought settled in and the basin became more arid. Resources became scarce. Adding to already stressed populations, evidence indicates that periodic flooding of the Salt River impacted much of the agricultural land. It was during this period that people began to aggregate to the higher elevations in the Tonto cliff dwellings.
The cliff dwellings of Tonto National Monument were constructed in natural recesses in siltstone hills surrounding Tonto Basin. Protected by the arid environment and from direct contact by the elements, the dwellings are remarkably well preserved. The Salado people used mud, rocks, and wood to construct multistory dwellings, or pueblos. The Lower Cliff Dwelling consisted of 16 rooms on the ground floor—three having a second story. Adjacent to the primary structure was a 12-room annex. The Upper Cliff Dwelling consisted of 32 rooms on the ground floor, eight of which had second stories. By about AD 1450, the Salado people had abandoned Tonto Basin.
Jabon Eagar
Park Purpose
The purpose statement identifies the specific reason(s) for establishment of a particular park. The purpose statement for Tonto National Monument was drafted through a careful analysis of its enabling legislation and the legislative history that influenced its development.
The monument was established when President Theodore Roosevelt signed Presidential Proclamation No. 787 on December 19, 1907 (see appendix A for presidential proclamations). The purpose statement lays the foundation for understanding what is most important about the park.
The purpose of Tonto National Monument is to preserve, protect, interpret, research, and manage 700-year-old Salado cliff dwellings, other archeological sites, artifacts, and the associated Sonoran Desert environment.
Jabon Eagar
Park Significance
Significance statements express why a park’s resources and values are important enough to merit designation as a unit of the national park system. These statements are linked to the purpose of Tonto National Monument, and are supported by data, research, and consensus. Statements of significance describe the distinctive nature of the park and why an area is important within a global, national, regional, and system-wide context. They focus on the most important resources and values that will assist in park planning and management.
The following significance statements have been identified for Tonto National Monument.
(Please note that the sequence of the statements does not reflect the level of significance.)
The distinctive Salado architecture at Tonto National Monument represents some of the best-preserved cliff dwellings in the American Southwest.
The complex Upland Sonoran Desert environment at Tonto National Monument has led to diverse types of archeological resources and a high site density, representing a broad range of cultural groups extending for more than 10,000 years.
Natural and cultural resources within Tonto National Monument are significant to a number of contemporary American Indian tribes, as evidenced by oral history and continuing traditional practices.
Fundamental Resources and Values
Fundamental resources and values (FRVs) are those features, systems, processes, experiences, stories, scenes, sounds, smells, or other attributes determined to warrant primary consideration during planning and management processes because they are essential to achieving the purpose of the park and maintaining its significance. Fundamental resources and values are closely related to a park’s legislative purpose and are more specific than significance statements.
Fundamental resources and values help focus planning and management efforts on what is truly significant about the park. One of the most important responsibilities of NPS managers is to ensure the conservation and public enjoyment of those qualities that are essential (fundamental) to achieving the purpose of the park and maintaining its significance. If fundamental resources and values are allowed to deteriorate, the park purpose and/or significance could be jeopardized.
The following fundamental resources and values have been identified for Tonto National Monument:
Cliff Dwellings: The five prehistoric cliff dwellings at Tonto National Monument, especially the iconic Upper and Lower Cliff Dwellings, are remarkably well preserved and act as the type site for Salado cliff dwellings. They showcase a mixture of southern and northern architecture within the larger Salado Cultural Complex. Due to the preservation of the ruins, their intact roofs, and the presence of unexcavated cultural fill, the 700-year-old dwellings are important research sites that have yielded extensive information regarding the material culture and subsistence practices of the Salado people and demonstrate the evolution of the science of archeology.
Museum Collection: Tonto’s museum collection contains well-preserved artifacts associated with the Salado cliff dwellings and other archeological sites in the monument. Prehistoric sandals, detailed polychrome pottery, woven cotton garments, and perishable foods such as corn and agave have been preserved here for centuries, while other artifacts such as spear points and agricultural implements are evidence of millennia of occupation in the area. Textiles from the Tonto National Monument museum collection include some of the finest prehistoric examples in North America (relative to quantity, degree of preservation, variety of weaves, and weaving techniques).
Tonto National Monument Archeological District: In addition to the two major cliff dwellings, the monument comprises a well-protected sample of Archaic Period hunters, the Salado occupation, later Apache and Yavapai camps, and historic European American settlements of the upland portion of the Tonto Basin, reflecting changes in human adaptation over perhaps 10,000 years. The extremely dense array of archeological sites includes human occupation represented by rock shelters, field houses, pueblos, and cliff dwellings.
Upper Sonoran Desert Setting: The variegated Sonoran Desert setting of the monument has been integral to each of the cultures that settled in the Tonto Basin. Ridge tops and caves provided shelter, while steep slopes and canyon bottoms provided wild food resources and water. The monument’s perennial springs, abundant flora and fauna, sweeping vistas, and diverse terrain made it possible to subsist in such a harsh environment. This landscape (largely unchanged over the millennia) helps visitors imagine life as it once was for the Salado people and other cultures that lived in the area.
Jabon Eagar
Interpretative Themes
Interpretive themes are often described as the key stories or concepts that visitors should understand after visiting a park—they define the most important ideas or concepts communicated to visitors about a park unit. Themes are derived from, and should reflect, park purpose, significance, resources, and values. The set of interpretive themes is complete when it provides the structure necessary for park staff to develop opportunities for visitors to explore and relate to all park significance statements and fundamental resources and values.
Interpretive themes are an organizational tool that reveal and clarify meaning, concepts, contexts, and values represented by park resources. Sound themes are accurate and reflect current scholarship and science. They encourage exploration of the context in which events or natural processes occurred and the effects of those events and processes.
Interpretive themes go beyond a mere description of the event or process to foster multiple opportunities to experience and consider the park and its resources. These themes help explain why a park story is relevant to people who may otherwise be unaware of connections they have to an event, time, or place associated with the park.
The following interpretive themes have been identified for Tonto National Monument:
Tonto National Monument’s well-preserved Salado cliff dwellings and diverse artifacts in the upper Sonoran Desert provide opportunities to experience a thriving culture deeply rooted in its natural setting, provoking contemplation of our own connections to nature.
The beautiful and complex craftsmanship evidenced by Salado architecture, pottery, textiles, and other artifacts—influenced by the continuous movement of people and ideas—boldly exemplifies how cultural identity and the value of aesthetic expression were and continue to be essential to society.
For at least 10,000 years, the Tonto Basin area has provided, and continues to provide, a home to many diverse people, emphasizing past and present ties to home and heritage.
Jabon Eagar
Part 2: Dynamic Components
The dynamic components of a foundation document include special mandates and administrative commitments and an assessment of planning and data needs. These components are dynamic because they will change over time. New special mandates can be established and new administrative commitments made. As conditions and trends of fundamental resources and values change over time, the analysis of planning and data needs will need to be revisited and revised, along with key issues. Therefore, this part of the foundation document will be updated accordingly.
Special Mandates and Administrative Commitments
Many management decisions for a park unit are directed or influenced by special mandates and administrative commitments with other federal agencies, state and local governments, utility companies, partnering organizations, and other entities. Special mandates are requirements specific to a park that must be fulfilled. Mandates can be expressed in enabling legislation, in separate legislation following the establishment of the park, or through a judicial process.
They may expand on park purpose or introduce elements unrelated to the purpose of the park. Administrative commitments are, in general, agreements that have been reached through formal, documented processes, often through memorandums of agreement. Examples include easements, rights-of-way, arrangements for emergency service responses, etc. Special mandates and administrative commitments can support, in many cases, a network of partnerships that help fulfill the objectives of the park and facilitate working relationships with other organizations. They are an essential component of managing and planning for Tonto National Monument.
There are no special mandates for Tonto National Monument. For more information about the existing administrative commitments for Tonto National Monument, please see appendix B.
Assessment of Planning and Data Needs
Once the core components of part 1 of the foundation document have been identified, it is important to gather and evaluate existing information about the park’s fundamental resources and values, and develop a full assessment of the park’s planning and data needs. The assessment of planning and data needs section presents planning issues, the planning projects that will address these issues, and the associated information requirements for planning, such as resource inventories and data collection, including GIS data.
There are three sections in the assessment of planning and data needs:
Analysis of fundamental resources and values.
Identification of key issues and associated planning and data needs.
Identification of planning and data needs (including spatial mapping activities or GIS maps).
The analysis of fundamental resources and values and identification of key issues leads up to and supports the identification of planning and data collection needs.
Analysis of Fundamental Resources and Values
The fundamental resource or value analysis table includes current conditions, potential threats and opportunities, planning and data needs, and selected laws and NPS policies related to management of the identified resource or value.
Fundamental Resource or Value
Cliff Dwellings
Related Significance Statements
The distinctive Salado architecture at Tonto National Monument represents some of the best-preserved cliff dwellings in the American Southwest.
Natural and cultural resources within Tonto National Monument are significant to a number of contemporary American Indian tribes, as evidenced by oral history and continuing traditional practices.
Current Conditions and Trends
Conditions
The Upper and Lower Cliff Dwellings are in good condition; however, there is evidence of degrading of previous restoration efforts.
Preventive and cyclic maintenance of the cliff dwellings is up to date.
Considerable resources have been expended on comprehensive preservation projects involving multiple issues in both the Upper and Lower Cliff Dwellings.
Major stabilization of key areas of the cliff dwellings has been completed.
Over time, multiple preservation techniques have been used on both the Upper and Lower Cliff Dwellings. Some of the early preservation techniques have had unintended consequences and have at times negatively impacted the quality of the site. For example, in some areas the use of cement over an adobe substrate trapped moisture and increased the potential for erosion of walls.
Due to staff constraints, the number of visitors who can access and visit the larger Upper Cliff Dwelling is limited.
Increasing vandalism has occurred in room (2), and in open area (11) at Lower Cliff Dwelling between 2014 and 2016; the large historic patch darkened from soot accumulation now has issues with graffiti.
Visitors’ pets are no longer allowed access to the cliff dwellings but are required to stop just below access to the ruins at covered shelters.
The primary visitor access trail to the Lower Cliff Dwelling is in good condition; shade structures have been erected for visitor comfort and safety.
Trends
Structures are stable due to ongoing preservation and management activities.
Although graffiti in some areas has increased, conditions may improve due to an increased presence of on-site park rangers and volunteers.
Threats and Opportunities
Threats
Weather, such as large precipitation events, causes water infiltration into the cliff dwellings Some pooling at retaining structures accelerates erosion and damages the ruins Water at times has saturated the walls and grounds This condition can cause large chunks of adobe structured walls to slough off.
Visual integrity of the structures has been compromised in some areas as a result of past preservation activities. Mismatched materials and associated erosion can impact the nature and quality of visitor experiences.
Historic and untested long-term preservation techniques of adobe structures have at times accelerated and continue to add to structural erosion and structural degradation.
Rodent disturbance (pack rats, squirrels, and others) in the ruins causes erosion and weakens structures. The presence of harmful predators creates a potentially unsafe condition for visitors.
Nesting birds and bats on the cliffs have led to spalling of cliff faces and unsightly buildup of guano on structures.
Nesting Africanized bees have been a threat to visitors; subsequent treatment activities risk dislodging cliff face boulders and injury to monument staff or contractors.
As visitation numbers increase, the potential of resource damage increases through accidental or deliberate human stresses.
Access to cliff dwelling ruins is not compliant with the Americans with Disabilities Act (ADA) Even within the ruins, the steps are uneven and not uniform This can pose a potential threat to the elderly / mobility impaired.
Ground-level ozone can reach levels that can make breathing difficult for sensitive groups including children, the elderly, and people with existing health problems.
Wood beams, lintels, thresholds, roofs, etc , used in dwelling construction are threatened by fire and wood-boring insects as well as long-term organic matter degradation and breakdown.
Unrestricted visitor activities such as tampering with wood plugs, urinating or defecating on walls or floors in the ruin, leaning or sitting on walls, unsupervised children playing on ruins, leaving litter, food, or beverages in the ruins, and inadvertently kicking the base of walls damages structures.
The monument’s proximity to Globe, Arizona, and Roosevelt Reservoir (a large recreation area) has led to after-hours exploration and unauthorized access and inappropriate use of monument features.
Illegal excavation and theft of prehistoric objects and vandalism of monument resources threatens resources.
Rockfalls, especially after storms, are hazards for both resources and visitors.
Extreme weather events due to climate change and associated impacts can potentially damage resources. For example, projected rises in temperature and aridity can increase the frequency and intensity of wildland fires that may threaten the dwellings.
Helicopter flyovers and low flying aircraft increase sonic vibrations and noise levels leading to cliff face degradation and potentially damaging ruins and impacting visitor experience.
Threats and Opportunities
Opportunities
Add staff and volunteers to increase public access to the ruins and allow more visitation to the Upper Cliff Dwelling.
Continue to provide interpretive outreach programing in Globe, Arizona, for STEM (Science, Technology, Engineering, and Mathematics) festival to promote education and preservation of monument resources.
Partner with Northern Arizona University in developing technologies such as interactive touch screens, websites, and virtual tours of the cliff dwellings. This would allow visual access to those unable to hike to the cliff dwellings.
Continue the fourth-grade pass program (free admission for fourth graders who do an online activity) and work to ensure that fourth graders have every opportunity to visit the monument.
Actively develop new and engaging public archeology programs (making sandals, lighting fires) to help visitors of all ages connect with the people and the place.
Continue to support partnerships with the City of Globe’s archeology site “Besh ba Gowah” (a Salado culture surface pueblo) The two units would continue to support interpretive programing and opportunities to expand visitors’ abilities to learn about the Salado culture.
Continue to actively engage with federal partners such as the U S Forest Service, Bureau of Reclamation, and Bureau of Land Management in archeological site protection, preservation, and education.
Continue to participate and actively support the “Junior Archeologist Program ” This program connects 10 cultural heritage sites throughout Arizona.
Develop multiple youth engagement projects related to monument resources and dwellings that would serve broad and diverse audiences. Encourage high school and middle school students to visit the monument to study and use as an outdoor classroom.
Strengthen and improve engagement and outreach to traditionally associated tribes. Mutual projects such as the development of a community garden could lead to more tribal youth engagement. Develop projects that share American Indian perspectives about the cliff dwellings through interactive touch screens or related media with monument visitors.
Continue collaborating with the NPS Vanishing Treasures program staff on state-of-the-art preservation methods.
The monument is continuing to work with Gila County to expand educational opportunities at the monument.
Investigate participating in a local ozone advisory program.
Data and/or GIS Needs
Visitor capacity study / visitor use study.
LiDAR rescanning of cliff dwellings (last done in 2007–2009) within 10 years to analyze structural or surface degradation.
Collect and analyze climate change data.
Accessibility assessment.
Planning Needs
Visitor use management plan.
Complete ruins preservation plan.
Accessibility conceptual site plan.
Resource stewardship strategy.
Laws, Executive Orders, and Regulations That Apply to the FRV, and NPS Policy-level Guidance
Laws, Executive Orders, and Regulations That Apply to the FRV
Antiquities Act of 1906.
Historic Sites Act of 1935.
National Historic Preservation Act of 1966, as amended.
Archeological and Historic Preservation Act of 1974.
American Indian Religious Freedom Act of 1978.
Archaeological Resources Protection Act of 1979.
Native American Graves Protection and Repatriation Act of 1990.
Museum Properties Management Act of 1955, as amended.
Executive Order 11593, “Protection and Enhancement of the Cultural Environment”.
Executive Order 13007, “Indian Sacred Sites”.
“Curation of Federally-Owned and Administered Archaeological Collections” (36 CFR 79).
“Protection of Historic Properties” (36 CFR 800).
Secretarial Order 3289, “Addressing the Impacts of Climate Change on America’s Water, Land, and Other Natural and Cultural Resources” NPS Policy-level Guidance (NPS Management Policies 2006 and Director’s Orders).
Director’s Order 24: NPS Museum Collections Management • Director’s Order 28: Cultural Resource Management.
Director’s Order 28A: Archeology.
NPS Museum Handbook, parts I, II, and III.
The Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation.
Fundamental Resource or Value
Museum Collection
Related Significance Statements
The distinctive Salado architecture at Tonto National Monument represents some of the best-preserved cliff dwellings in the American Southwest.
The complex Upland Sonoran Desert environment at Tonto National Monument has led to diverse types of archeological resources and a high site density, representing a broad range of cultural groups extending for more than 10,000 years.
Natural and cultural resources within Tonto National Monument are significant to a number of contemporary American Indian tribes, as evidenced by oral history and continuing traditional practices.
Current Conditions and Trends
Conditions
Most of the monument museum collection is at the NPS Western. Archeological and Conservation Center except for those objects and archives on display in visitor center exhibits.
Conditions are excellent for all collections; however, some textiles are awaiting conservation work based on a Cooperative Ecosystem Studies Unit agreement.
Collections are accessed infrequently for research Research permitting and collecting objects is infrequent.
There are approximately 56,000 objects in the museum collection. They consist of a diverse range of Salado material culture, both organic and inorganic, that have been collected over a long period of time.
The monument archive collection totals approximately 63,000 pieces. They represent records of monument history, early photos, and images of monument resources More than 5,000 photos are digitally archived.
All monument objects and archives are logged in the Interior Collections Management System (ICMS) database.
Monument collections are securely held to NPS standards at the NPS Western Archeological and Conservation Center.
All collections on display at the monument are secure, and data recorders monitor environmental conditions inside exhibit cases and are reviewed daily by monument staff.
Organic and perishable items on exhibit display are on a timed rotation schedule with the NPS Western Archeological and Conservation Center.
Trends
Monument collections are stable to improving due to management actions.
The NPS Western Archeological and Conservation Center is actively working on curation and conservation of monument collections.
Threats and Opportunities
Threats
Theft of cultural items displayed at the monument visitor center; objects have been stolen in the past.
Contamination or insect infestation of organic materials on display Up to this time, the monument has had no issues.
Water damage from mold and rot could cause considerable damage to display items.
Improper humidity and excess ultraviolet light can damage textiles and fade colors.
Improper handling of museum objects during maintenance or transfer increases the risk of breakage or contamination.
Threats and Opportunities
Opportunities
The monument would benefit from better access to the collections database to help support on-site research and virtual exhibits.
Monument collections continue to be of high value to science through artifact analysis and study.
The monument continues to provide high-quality educational opportunities for interpreting artifacts and prehistoric Salado lifestyle through both on-site access and web-based virtual experiences.
Continue to support external showings and interpretation of Tonto National Monument artifacts at the Phoenix Airport Museum inside Sky Harbor International Airport.
Partnering with the Museum of Northern Arizona University for a virtual museum would increase access to monument resources to a broader audience.
Data and/or GIS Needs
Long-term monitoring of artifact conditions in exhibit cases.
Planning Needs
Comprehensive interpretive plan.
Laws, Executive Orders, and Regulations That Apply to the FRV, and NPS Policy-level Guidance
Laws, Executive Orders, and Regulations that apply to the FRV
Antiquities Act of 1906.
National Historic Preservation Act of 1966, as amended.
Archeological and Historic Preservation Act of 1974.
American Indian Religious Freedom Act of 1978.
Archaeological Resources Protection Act of 1979.
Native American Graves Protection and Repatriation Act of 1990.
Museum Properties Management Act of 1955, as amended.
Paleontological Resources Preservation Act of 2009.
Executive Order 13007, “Indian Sacred Sites”.
“Curation of Federally-Owned and Administered Archaeological Collections” (36 CFR 79).
Secretarial Order 3289, “Addressing the Impacts of Climate Change on America’s Water, Land, and Other Natural and Cultural Resources”.
NPS Policy-level Guidance (NPS Management Policies 2006 and Director’s Orders)
NPS Management Policies 2006 (§4 2) “Studies and Collections”.
NPS Management Policies 2006 (§5 1) “Research”.
NPS Management Policies 2006 (§8 10) “Natural and Cultural Studies, Research, and Collection Activities”.
Director’s Order 24: NPS Museum Collections Management.
Director’s Order 28: Cultural Resource Management.
Director’s Order 28A: Archeology.
NPS Museum Handbook, parts I, II, and III.
Fundamental Resource or Value
Tonto National Monument Archeological District
Related Significance Statements
The distinctive Salado architecture at Tonto National Monument represents some of the best-preserved cliff dwellings in the American Southwest.
The complex Upland Sonoran Desert environment at Tonto National Monument has led to diverse types of archeological resources and a high site density, representing a broad range of cultural groups extending for more than 10,000 years.
Current Conditions and Trends
Conditions
The Tonto National Monument Archeological District is listed in the National Register of Historic Places.
Complete site conditions are available through the Archeological Site Management Information System (ASMIS) database for 80 sites Most sites are in fair to good condition.
About 100 new sites have been identified through a historic site survey Monument staff is waiting on the new survey before the sites are entered into ASMIS.
A few sites are no longer viable.
The Archaic Period evidence and sites represented in the monument are in good condition. The Salado culture sites are in fair to good condition; some have erosion issues Early Yavapai Apache occupation sites are in good condition More information of historic era sites is required to determine condition.
There is evidence of historic looting of critical sites.
Access to some surface sites is not available to the visiting public. Many specific sites are in pristine condition with objects and artifacts exposed on the surface.
The monument monitors and manages “Saddle Site,” which is primarily on U S Forest Service land (managed through interagency agreement).
All sites on a monitoring schedule for condition assessments are up to date.
Trends
A majority of the sites have been in good, stable condition since 2008.
The condition of some sites is declining due to erosion. This is fairly evident for sites next to drainages.
Threats and Opportunities
Threats
Erosion and damage to sites next to drainages, especially after significant precipitation events. For example, approximately nine inches of rain in a single event in 2016 created significant drainage issues.
Theft and vandalism of monument features. Visitors are allowed close access to features, often in large groups, and can move freely at times unsupervised. After-hours illegal access has at times been a problem and has led to theft and vandalism.
Wildfire has the potential for extensive damage of surface structures and evidence Damage can be caused both by the fire and by fire suppression.
Trespassing cattle from grazing allotments on nearby U. S. Department of Agriculture (USDA) Forest Service land have caused direct damage to sites and potential damage from erosion.
Native and nonnative animal damage can result from trailing, burrowing, and nesting.
Growing vegetation, either on the cliff faces or along the surface, can attract animals, and roots can cause damage.
Climate change and its associated impacts can threaten resources. Examples might be temperature change along with major precipitation events and seasonal unpredictability.
Opportunities
The monument’s preservation of numerous archeological sites covering a broad chronological spectrum of diverse data provides multiple research opportunities for a broad range of disciplines.
Threats and Opportunities
Opportunities (continued)
Continue to engage in partnerships with universities (e g , Northern Arizona University and others) through Cooperative Ecosystem Studies Unit agreements, internships, and as an outdoor classroom.
Continued understanding of evidence and contemporary research has provided relevant and accurate interpretation not just at Tonto National Monument but at other nearby NPS units and education institutions.
Foster and encourage research on a heavily impacted field house for remaining evidence and educational and interpretive potential.
Collaboration with Tonto National Forest for management, preservation, restoration, and interpretation of “Saddle Site” (a surface pueblo on the monument boundary).
Data and/or GIS Needs
Baseline data on conditions of newly recorded historic sites.
Planning Needs
Invasive species management plan.
Comprehensive interpretative plan.
Accessibility conceptual site plan.
Resource stewardship strategy.
Laws, Executive Orders, and Regulations That Apply to the FRV, and NPS Policy-level Guidance
Laws, Executive Orders, and Regulations that apply to the FRV
National Historic Preservation Act of 1966, as amended.
Antiquities Act of 1906 • Archeological and Historic Preservation Act of 1974.
Archaeological Resources Protection Act of 1979.
American Indian Religious Freedom Act of 1978.
Museum Properties Management Act of 1955, as amended.
Native American Graves Protection and Repatriation Act of 1990.
Lacey Act, as amended
Executive Order 11593, “Protection and Enhancement of the Cultural Environment”.
Executive Order 13007, “American Indian Sacred Sites”.
“Curation of Federally-Owned and Administered Archaeological Collections” (36 CFR 79).
Secretarial Order 3289, “Addressing the Impacts of Climate Change on America’s Water, Land, and Other Natural and Cultural Resources”.
NPS Policy-level Guidance (NPS Management Policies 2006 and Director’s Orders)
NPS Management Policies 2006 (§8 10) “Natural and Cultural Studies, Research, and Collection Activities”.
Director’s Order 24: NPS Museum Collections Management.
Director’s Order 28: Cultural Resource Management.
Director’s Order 28A: Archeology.
NPS Museum Handbook, parts I, II, and III.
The Secretary of the Interior’s Standards and Guidelines for Archeology and Historic Preservation.
Fundamental Resource or Value
Upper Sonoran Desert Setting
Related Significance Statements
The complex Upland Sonoran Desert environment at Tonto National Monument has led to diverse types of archeological resources and a high site density, representing a broad range of cultural groups extending for more than 10,000 years.
Natural and cultural resources within Tonto National Monument are significant to a number of contemporary American Indian tribes, as evidenced by oral history and continuing traditional practices.
Current Conditions and Trends
Conditions
Based on the NPS Inventory and Monitoring Program’s Sonoran Desert Network, the majority of the ecosystem is intact and in good condition.
Information on the monument’s water table was evaluated by the Washington Office Natural Resources Stewardship and Science Division and the groundwater is stable.
Trends
Policy changes in wildfire management by the U S Forest Service call for a reduction in active management.
Threats and Opportunities
Threats
Wildfire can threaten structures and habitats Mitigation of wildfires can cause erosion or surface site disruption.
Climate change and its associated impacts Extended precipitation events or prolonged regional drought could cause significant changes in the ecosystem.
Invasive species introduced into the area. For example, bufflegrass is trying to take hold in the area (bufflegrass burns much hotter than native species) Red brome, Sahara mustard, and wild oats have infiltrated the monument and require managed removal.
Diseases such as white-nose syndrome have the potential for significant impact to an active bat population.
Off-road driving can damage critical surface archeological sites and critical habitat.
Visitors hiking off-trail can cause erosion and potential damage to surface archeological sites.
Power lines and the highway through easements on monument land are pathways for invasive species that damage saguaros and at times have harmed avian wildlife.
Reduced flow levels and changes in water quality of an active spring at the monument threaten monument fora and fauna and operations.
People killing perceived dangerous wildlife (snakes) and other native wildlife can disrupt natural predator/prey relationships.
Air pollution from coal-fired power plants, vehicle exhaust, fire, dust, and agriculture may be causing harmful impacts and mercury contamination to ozone-sensitive plants.
Opportunities
Continue to partner with the NPS Sonoran Desert Network to monitor springs, vegetation plots, and bird surveys (Mexican spotted owl).
Partner with U S Forest Service for managing lands that border the monument. This could include fire management, cattle management, and watershed management.
Continue partnering with the NPS Southwest Exotic Plant Management Team to monitor and eradicate nonnative species, map invasive species, and prevent future invasions.
Encourage research and partnerships with universities to study climate change.
Partner with Arizona Game and Fish and the U S Fish and Wildlife Service to monitor riparian areas in the monument and related studies.
Partner with the Audubon Society for outreach and education tools to take advantage of the high number of species present in the monument.
Data and/or GIS Needs
Collect GIS fire data from land surrounding the monument.
Study of Cave Canyon watershed and associated grazing impacts.
Collect and analyze climate change data.
Planning Needs
Rangeland management plan.
Climate change scenario planning.
Resource stewardship strategy.
Laws, Executive Orders, and Regulations That Apply to the FRV, and NPS Policy-level Guidance
Laws, Executive Orders, and Regulations That Apply to the FRV
Endangered Species Act of 1973, as amended.
National Invasive Species Act.
Lacey Act, as amended.
Migratory Bird Treaty Act.
Bald and Golden Eagle Protection Act.
National Environmental Policy Act of 1969.
Federal Noxious Weed Act of 1974, as amended.
Clean Water Act.
Clean Air Act (42 USC 7401 et seq ).
Paleontological Resources Preservation Act of 2009.
Executive Order 11514, “Protection and Enhancement of Environmental Quality”.
Executive Order 13112, “Invasive Species”.
Secretarial Order 3289, “Addressing the Impacts of Climate Change on America’s Water, Land, and Other Natural and Cultural Resources”.
Executive Order 13175, “Consultation and Coordination with Indian Tribal Governments”.
NPS Policy-level Guidance (NPS Management Policies 2006 and Director’s Orders)
NPS Reference Manual 18: Wildland Fire Management.
Identification of Key Issues and Associated Planning and Data Needs
This section considers key issues to be addressed in planning and management and therefore takes a broader view over the primary focus of part 1. A key issue focuses on a question that is important for a park. Key issues often raise questions regarding park purpose and significance and fundamental resources and values. For example, a key issue may pertain to the potential for a fundamental resource or value in a park to be detrimentally affected by discretionary management decisions.
A key issue may also address crucial questions that are not directly related to purpose and significance, but which still affect them indirectly. Usually, a key issue is one that a future planning effort or data collection needs to address and requires a decision by NPS managers.
The following are key issues for Tonto National Monument and the associated planning and data needs to address them:
Visitors’ ability to move safely through the monument is of primary concern to monument staff. Monument visitors are encouraged to explore the visitor center as the first stop of their tour. The visitor center provides informative exhibits and important safety information about the monument, including extreme temperatures, venomous reptiles and insects, and cacti. A visitor use management plan could develop programing that builds on the monument’s safety protocols and expand access to monument features in a safe and resource-friendly way. Other concerns are visitor use during peak times that results in lack of parking availability, and oversized vehicle management.
Associated planning and data need: visitor use management plan, visitor capacity study / visitor use study
Accessibility for visitors and staff to monument resources and interpretive programs is lacking. The monument would benefit by developing an accessibility conceptual site plan. This tool would allow the park to review its current levels of accessibility and identify specific opportunities for improvement. This would ensure that all monument facilities and amenities incorporate universal design into planned work.
Associated planning and data need: accessibility conceptual site plan, accessibility assessment
Invasive species, especially Africanized honey bees, present issues for employees, visitor safety, and archeological resources. Some mitigation treatments are hazardous, requiring skills in canyoneering as well as safe extermination and removal. Concerns are the potential for dislodging sections of the cliff face, resulting in employee and visitor safety and resource damage.
Associated planning and data need: invasive species management plan
Tonto National Monument is a key resource in the archeological history of the Salado culture. Information collected here has changed the understanding of the prehistoric Southwest and has far-reaching ramifications for understanding the complex relationships of related Southwest cultures. The monument depends on active, broad academic support to interpret and piece together the information in meaningful ways. Working with existing partners can support ongoing research; however, identifying new partners and organizations could facilitate needed research along with communicating current knowledge to a broader audience.
Associated planning and data need: park partner action strategy / community partner assessment
Planning and Data Needs
To maintain connection to the core elements of the foundation and the importance of these core foundation elements, the planning and data needs listed here are directly related to protecting fundamental resources and values, park significance, and park purpose, as well as addressing key issues. To successfully undertake a planning effort, information from sources such as inventories, studies, research activities, and analyses may be required to provide adequate knowledge of park resources and visitor information. Such information sources have been identified as data needs.
Geospatial mapping tasks and products are included in data needs. Items considered of the utmost importance were identified as high priority, and other items identified, but not rising to the level of high priority, were listed as either medium- or low-priority needs. These priorities inform park management efforts to secure funding and support for planning projects.
Planning Needs-Where a Decision-Making Process is Needed
Related to an FRV or Key Issue?
Planning Needs
Priority (H, M, L)
Notes
FRV and Key Issue
Visitor use management plan
H
A visitor use management plan is needed to address visitor safety issues (bees, snakes, cacti, and harsh environment). It would be a useful tool to expand opportunities for interpretation and recreation and manage visitor impacts on resources.
FRV
Comprehensive interpretive plan
H
The monument has recently completed new interpretive themes and needs a plan to integrate these into monument programming.
FRV and Key Issue
Accessibility conceptual site plan
H
Areas and critical features in the monument are inaccessible to some visitors. Understanding how the monument could expand accessibility for all and ensuring programs are fully usable is a high priority Instituting universal design standards for all monument structures and programs is an important goal.
FRV
Complete ruins preservation plan
M/H
A draft plan is in progress and partially contracted out It would provide guidance on conducting ruins preservation while taking into account the sensitivity of the resource.
FRV and Key Issue
Invasive species management plan
M
Although mitigation techniques for other invasive species are working, the issues with Africanized bees require more specific focus. This plan would assist in safely managing this hazardous invasive pest and other invasive species.
FRV
Resource stewardship strategy
M
This document would provide strategies to achieve the desired natural and cultural resource conditions.
Key Issue
Park partner action strategy / community partner assessment
M
This strategy would assist in identifying new partners and working effectively with existing partners. Although not an immediate need, nor one that impacts resources, this planning need aligns with monument goals.
FRV
Rangeland management plan
L
Grazing is allowed in areas near or bordering the monument. Although it is rare for cattle to trespass, having the tools to address this would be useful.
FRV
Climate change scenario planning
L
The monument is in the data collection phase.
Data Needs – Where Information Is Needed Before Decisions Can Be Made
Related to an FRV or Key Issue?
Data and GIS Needs
Priority (H, M, L)
Notes, Including Which Planning Need This Data Need Relates To
FRV and Key Issue
Visitor capacity study / visitor use study
H
Visitor use management planning was identified as a high priority. The data would inform resources, facilities, and interpretation and assist all divisions in their operations.
FRV and Key Issue
Accessibility assessment
H
This assessment would inform the accessibility conceptual site plan.
FRV
Baseline data on conditions of newly recorded historic sites
H
These data would help protect newly documented sites. Currently, there are no baseline data, and the sites are not on a monitoring schedule The 30 new sites will create an additional workload.
FRV
LiDAR rescanning of cliff dwellings (last done 2007– 2009) within 10 years to analyze structural or surface degradation
M
These data would help with studying comparative data over time. The monument currently has staff with skills in LiDAR Although not vital, these data would help to quantify what contributed to resource damage.
FRV
Collect and analyze climate change data
M
These data would inform climate change planning. Not an immediate need but could be an important future need.
FRV
Long-term monitoring of artifact conditions in exhibit cases
M
Monitoring verifies that the monument display cases are functioning properly. This monitoring would be done internally as an operational issue.
FRV
Study Cave Canyon watershed and associated grazing impacts
M
Primary information that would be useful is how grazing impacts the watershed. Not many external issues beyond this. Has been a decade at least since this issue has been monitored. Previous data almost resulted in a land swap where the National Park Service would take acreage on other side of the highway Would open discussion with the U S Forest Service about management of the watershed.
FRV
Collect GIS fire data from land surrounding the monument
L
The monument’s fire management plan is reviewed every year. Historic data on fires near the monument would help staff understand threats and how vegetation communities react to fires around the monument.
Part 3: Contributors
Tonto National Monument
Roger Dorr, Chief of Resource Management
Cinda Ewing, Facilities Operations Specialist
Charlene Hodson, Administrative Assistant
Duane Hubbard, Superintendent
Libby Schaaf, Chief of Interpretation
Wanda Gray Laferty, Contract Editor (former), Denver Service Center, Planning Division
Nancy Shock, Foundation Coordinator, Denver Service Center, Planning Division
Philip Viray, Publications Chief, Denver Service Center, Planning Division
Alex Williams, Natural Resource Specialist, Denver Service Center, Planning Division
John Paul Jones, Visual Information Specialist, Denver Service Center, Planning Division
Laura Watt, Contract Editor, Denver Service Center, Planning Division
Pam Holtman, Quality Assurance Coordinator, WASO Park Planning and Special Studies
Appendixes
Appendix A: Presidential Proclamations for Tonto National Monument
By the President of the United States of America
A PROCLAMATION
WHEREAS two prehistoric ruins of ancient cliff dwellings situated upon public lands of the United States, and located in the region commonly known as the Tonto Drainage Basin, about two miles south of the Salt River Reservoir, Gila County Arizona, are of great ethnological, scientific and educational interest, and it appears that the public interests would be promoted by reserving these relics of a vanished people as a National Monument with as much land as may be necessary for the proper protection thereof;
Now, therefore, I,Theodore Roosevelt, President of the United States of America, by virtue of the power in me vested by section two of the Act of Congress approved June 8, 1906, entitled, "An Act of Preservation of American Antiquities," do hereby set aside as the Tonto National Monument, subject to any valid interest or rights, the prehistoric cliff dwelling ruins and one section of land upon which same are located, situated in Gila County, Arizona, more particularly described as follows, to wit:
Section thirty-four, unsurveyed , in township four north, range twelve east of the Gila and Salt River Meridian, Arizona, as shown upon the diagram hereto attached and made a part of this Proclamation. Warning is hereby expressly given to all unauthorized persons not to appropriate, excavate, injure or destroy any of the prehistoric ruins or remains thereof declared to be a National Monument, or to locate or settle upon any of the lands reserved and made a part of said monument by the Proclamation.
IN WITNESS WHEREOF, have hereunto set my hand and caused the seal of the United States to be affixed.
Done at the City of Washington this 19th day of December in the year of our Lord one thousand nine hundred and seven, and of the Independence of the United States the one hundred and thirty-second.
Theodore Roosevelt
By the President,
Elihu Root
Enlarging the Tonto National Monument-Arizona
By the President of the United States of America
A PROCLAMATION
WHEREAS the area in the State of Arizona established as the Tonto National Monument by Proclamation of December 19, 1907, has situated thereon prehistoric ruins and ancient cliff dwellings which are of great ethnological and scientific, and educational interest to the public , and
WHEREAS is appears that there are certain government-owned lands reserved by Proclamation of January 13,1908, as a part of the Tonto National Forest , adjacent to the boundaries of said monument , which are required for the proper care, management, and protection of the said historic ruins and ancient cliff dwellings:
NOW, THEREFORE, I, FRANKLIN D. ROOSEVELT, President of the United States of America, under and by virtue of the authority vested in me by section of the act of June, 4,1907, ch. 2 30 Stat, 11,36 (U.S.C., title 16,sec. 473), and section 2 of the act of June 8, 1906, ch 3060, 34 Stat, 225 (U.S.C., title 16, sec. 431), do proclaim that, subject to all valid existing rights, the following-described lands in Arizona are hereby excluded from the Tonto National Forest and reserved from all forms of appropriation under the public-land laws and added to and make a part of the Tonto National Monument:
Gila and Salt River Meridian
Warning is hereby expressly given to all unauthorized person not to appropriate, injure, destroy, or remove any feature of the monument and not to locate or settle upon any of the land thereof.
The Director of the National Park Service, under the direction of the Secretary of the Interior, shall have the supervision, management, and control of this monument as provided in the act of Congress entitled "An Act To establish a National Park Service, and for other purposes", approved August 25,1916 (ch. 408, 39 Stat. 535, U.S.C., title 16, secs. 1 and 2), and acts supplementary thereto or amendatory thereof: Provided, that the administration of the monument shall be subject to the withdrawal for the Salt River Irrigation project, Arizona.
IN WITNESS WHEREOF, I have hereunto set my hand and caused the seal of the United States to be affixed.
DONE at the City of Washington this first day of April in the year of our Lord nineteen hundred and thirty-seven and of the Independence of the United States of America the one hundred, and sixty-first.
FRANKLIN D. ROOSEVELT
By the President,
Cordell Hull
The Secretary of State
Appendix B: Inventory of Administrative Commitments
Title / Agency / Organization
Purpose / Description
Expiration Date
Signatory
Local law enforcement
Park emergencies and law enforcement
Update pending
Gila County Sheriff
Local fire department agreement with Tonto Basin Fire Department
Mutual aid agreements for fire suppression and emergency medical service
Ongoing
Tonto Basin Fire District
Arizona Department of Environmental Quality
Air quality monitoring
Ongoing
State of Arizona
U S Forest Service
Tonto Basin Ranger District, Tonto National Forest for wildland fire suppression—2015 Interagency Annual Operating Plan
4/13/2018
Tonto National Forest
Northern Arizona University Anthropology Department (P12AC11020)
Part of larger agreement to create virtual museums and disseminate information to public for 10 southern Arizona parks
Requires modifications and renewal
University of Northern Arizona
University of Northern Arizona (P14AC01065)
Interpretive exhibits development
8/31/2019
University of Northern Arizona
Western National Parks Association
Partnership to provide interpretive materials
-
Western National Parks Association
Safety Zone Agreement
Sharing of zone safety officer
Not established
Tonto National Monument, Petrified Forest National Park, SOAR, MOCA/TUZI, FLAG Area Parks
Special use permit granted to Arizona Department of Transportation
200-foot-wide right-of-way for Arizona State Route 188 through monument
-
Arizona Department of Transportation
Special use permit granted to Arizona Telephone Company
Construction and maintenance of telephone lines across monument
-
Arizona Telephone Company
Special use permit granted to Salt River Project Agricultural Improvement and Power District
Right-of-way in monument
-
Salt River Project Agricultural Improvement and Power District
Appendix C: List of Traditionally Associated Tribes
Pueblo de Cochiti,New Mexico Pueblo de Cochiti Council PO Box 70 Cochiti, NM 87072 Fort McDowell Yavapai Nation,Arizona Fort McDowell Yavapai Tribal Council PO Box 17779 Fountain Hills, AZ 85268 Fort Sill Apache Tribe,Oklahoma Fort Sill Apache Business Committee Route 2, Box 121 Apache, OK 73006 Gila River Indian Community of the Gila River Indian Reservation,Arizona Gila River Indian Community Tribal Council PO Box 97 Sacaton, AZ 85247 Hopi Tribe,Arizona Hopi Tribal Council PO Box 123 Kykotsmovi, AZ 86039 Jicarilla Apache Nation, New Mexico Jicarilla Apache Tribal Council PO Box 507 Dulce, NM 87528 Mescalero Apache Tribe of the Mescalero Reservation, New Mexico Mescalero Apache Tribal Council PO Box 227 Mescalero, NM 88340 Pueblo of Nambe, New Mexico Nambe Pueblo Tribal Council Route 1, Box 117-BB Santa Fe, NM 87506 Navajo Nation, Arizona, New Mexico, and Utah Navajo Nation Tribal Council PO Box 7440 Window Rock, AZ 86515 Pueblo of Picuris, New Mexico Picuris Pueblo Tribal Council PO Box 127 Penasco, NM 87034 Pueblo of Acoma, New Mexico Pueblo of Acoma Tribal Administration PO Box 309 Acoma, NM 87506 Pueblo of Pojoaque, New Mexico Pueblo of Pojoaque Tribal Council 78 Cities of Gold Road Santa Fe, NM 87506 Salt River Pima-Maricopa Indian Community of the Salt River Reservation, Arizona Salt River Pima-Maricopa Indian Community Council 10005 East Osborn Road Scottsdale, AZ 85256 San Carlos Apache Tribe of the San Carlos Reservation, Arizona San Carlos Apache Tribal Council PO Box 0 San Carlos, AZ 85550 Tohono O’odham Nation of Arizona Tohono O’odham Tribal Council PO Box 837 Sells, AZ 85634 Tonto Apache Tribe of Arizona Tonto Apache Tribal Council Tonto Reservation #30 Payson, AZ 85541 Ak-Chin Indian Community of the Maricopa (Ak-Chin) Indian Reservation, Arizona Ak-Chin Indian Community Tribal Council 42507 West Peters and Nall Road Maricopa, AZ 85138 Apache Tribe, Oklahoma Apache Business Committee PO Box 1330 Anadarko, OK 73005-1220 White Mountain Apache Tribe of the Fort Apache Reservation, Arizona White Mountain Apache Tribal Council PO Box 700 Whiteriver, AZ 85941 Yavapai-Apache Nation of the Camp Verde Indian Reservation, Arizona Yavapai-Apache Tribal Council 400 West Datsi Street Camp Verde, AZ 86322 Yavapai-Prescott Indian Tribe Yavapai-Prescott Tribal Board Of Directors 530 East Merritt Prescott, AZ 86301-2038 Ysleta Del Sur Pueblo of Texas Ysleta Del Sur Pueblo Tribal Council PO Box 17579 El Paso, TX 79917 Zuni Tribe of the Zuni Reservation, New Mexico Pueblo of Zuni Tribal Council PO Box 339 Zuni, NM 87327-0339
Appendix D: Past and Ongoing Park Planning and Data Collection Efforts
Name
Type
Published
Road Inventory and Needs Study
Data Report (transportation needs)
1/1/1982
National Register of Historic Places – Archeological District
Nomination Form
10/1/1987
National Register of Historic Places – Lower Ruin
TONT: Background Documents Registration Form
3/8/1989
National Register of Historic Places – Upper Ruin
TONT: Background Documents Registration Form
3/8/1989
Statement for Management
Park Planning
12/1/1989
Autecology of Arizona Sycamore
Data Report
8/1/1990
Western Region Natural and Cultural Resources Management Plan
Park Planning
6/1/1991
Status of Nonnative Plant Species
Data Report
8/1/1992
Archeological Survey Plan for Western Region of NPS
Park Planning
1/1/1994
Historic Photographic Survey
Data Report
7/1/1995
Vegetation Inventory, Classification and Monitoring
