The morphotonemics of Ganda have been particularly troublesome to linguists trying to describe the tonal structure of Bantu languages. Ganda has three surface tones, and changes in the surface tones parallel changes in grammatical function only part of the time. The author has found that a description of Ganda tones becomes manageable if instead of comparing surface patterns the linguist looks for underlying entities and a set of ordered rules. This paper reports on (1) the kinds of units and rules that are needed for Ganda and (2) suggests some implications for comparative Bantu tonology. (DO)