As mentioned in the previous chapter, when action hooks were first introduced, the add_action function's third parameter is used to indicate the priority of a registered callback over other functions registered for the same hook (in this case, the admin_menu hook). To ensure that the newly created menu item is as high as possible in the menu, the priority of the registered function can be set to a value of 1:
add_action( 'admin_menu', 'ch2pho_settings_menu', 1 );
It should be noted that other plugins can also set their callback to this priority. In such cases, alphabetical priority and activation sequence are other factors to determine which menu item will be displayed first after Permalinks.