In In re Tanya H. (1993) 17 Cal.App.4th 825, the juvenile court reviewed a permanent plan submitted by DCFS, accepted the recommendations set forth therein, and ordered the subject minors to remain in long-term foster care. ( Tanya H., supra, 17 Cal.App.4th at p. 828.) Over the father's objection, the court then relieved his attorney pursuant to a written policy memorandum issued over the signature of the supervising judge of the dependency court. ( Id. at pp. 828-829.) On appeal, the court held that the father had no obligation to demonstrate a continuing "need" for counsel, that the need for counsel in the case of an interested, concerned parent is presumed. ( Id. at pp. 831-832.)