In In re Cody W. (1994) 31 Cal.App.4th 221, the court reviewed the line of California cases that have "made it clear that 'less severe alternatives' means no more than giving birth parents the opportunity to rehabilitate themselves and reunite with their families via court-ordered services before ordering the termination of their rights." (Id. at p. 229.) The concept "has never meant . . . that the juvenile court, at the selection and implementation hearing, must first consider long-term foster care or guardianship before adoption." (Id. at p. 230.) Indeed, "once efforts at reunification have been formally terminated, . . . section 366.26 clearly spells out the judicial options and, 'as a matter of public policy, the juvenile court gives first priority to adoption as the most desirable permanent plan.' " (Ibid.)