Historically, Lower Cretaceous strata in the Rocky Mountain region have been called the Dakota Formation based on assumed correlation with the type section of the Dakota of the Great Plains. Witzke and Ludvigson have argued that use of the name "Dakota" must reflect actual, not presumed correlation based on stratigraphy and composition of the sedimentary rock. To the west of the Rocky Mountains, such as on the Colorado Plateau, this sequence of Upper Cretaceous, predominately sandstone, sedimentary rocks was recommended to be known as the Dakota Group, to dispel any suggestion of direct facies correlation. However, few authors of papers on the Dakota west of the Rocky Mountains, especially on the Colorado Plateau, recognize the Dakota as the Dakota Group, instead using the term Dakota Sandstone, of formation rank. Its subdivisions are recognized as members. Many authors have emphasized the fact that the marine Dakota Sandstone on the Colorado Plateau is intertongued with the marine lower part of the Mancos Shale, resulting in valid lithostratigraphic names such as the Whitewater Arroyo Tongue of the Mancos Shale which is directly overlain by the Twowells Sandstone Tongue of the Dakota Sandstone. In the western San Juan Basin, the lowermost part of the Dakota Sandstone, although of marginal marine origin in the eastern San Juan Basin, is a complex of non-marine sandstones. These relationships are especially well displayed in the San Juan Basin of northwestern New Mexico