FROEHLICH, J. In In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922], we ruled that review of an order terminating reunification services and referring the case to a Welfare and Institutions Code section 366.26 selection and implementation hearing must be undertaken by petition for extraordinary writ, and cannot be mounted as an appeal from the later judgment rendered at the selection and implementation hearing. Our ruling on the motion to dismiss the appeal by mother in this case addresses the related issue of review of the same alleged error when it is packaged in the form of ineffective assistance of counsel for failing to file the timely writ petition.

This question turns on whether orders from a 12-month review and referral hearing under section 366.21 are reviewable in the context of an appeal from a subsequent section 366.26 permanency planning hearing, where no petition for extraordinary writ was filed from the decisions made at the earlier review and referral hearing. Recent cases have uniformly held that any review of an order terminating reunification services and determining that a child cannot be returned to a parent must be undertaken by writ petition, and if not so brought will be deemed waived. ( In re Arturo A. (1992) 8 Cal.App.4th 229, 234-237 [ 10 Cal.Rptr.2d 131] ; In re Amanda B. (1992) 3 Cal.App.4th 935, 941 [ 4 Cal.Rptr.2d 922]; In re Amber U. (1992) 3 Cal.App.4th 871, 879-881 [ 4 Cal.Rptr.2d 726]; In re Cory M. (1992) 2 Cal.App.4th 935, 945-947 [ 3 Cal.Rptr.2d 627]; In re Taya C. (1991) 2 Cal.App.4th 1, 6-9 [ 2 Cal.Rptr.2d 810].) (2) (See fn. 2.)

If the permanency planning order is erroneous, it is essential that such determination be made before the guardianship proceeding authorized by the order is conducted. (See In re Kristin W. (1990) 222 Cal.App.3d 234, 249 [ 271 Cal.Rptr. 629]; In re Taya C. (1991) 2 Cal.App.4th 1, 7-8 fn. 8 [ 2 Cal.Rptr.2d 810]; In re Matthew C. (1992) 3 Cal.App.4th 249, 261 [4 Cal.Rptr.2d 303]; In re Amanda B. (1992) 3 Cal.App.4th 935, 940 [ 4 Cal.Rptr.2d 922]]; Cynthia D. v. Superior Court (1992) 3 Cal.App.4th 913, 918-922 [4 Cal.Rptr.2d 909].) (1b) Here the petition for extraordinary relief was filed 16 months after the permanency planning order which it seeks to challenge and 7 months after the completion of the guardianship proceedings which were initiated on the authority of that order.

( In re Catherine S., supra, 230 Cal.App.3d at p. 1256; In re Rebecca H., supra, 227 Cal.App.3d at p. 837.) To do so routinely, however, would "undermine the Legislative objective of expediency and finality in child dependency administration" ( In reAmanda B. (1992) 3 Cal.App.4th 935, 942 [ 4 Cal.Rptr.2d 922]), and make a mockery of section 366.26, subdivision (k). Accordingly, it has been noted that such relief should be granted only "when the purported appeal was filed within the time that would have been appropriate for a writ filing — sufficiently early to allow [a reviewing] court's determination of the writ before" the juvenile court's ruling on the 366.26 hearing. ( Amanda B., supra, p. 941.)

The Court of Appeal's conclusion in this regard is consistent with the rulings in a number of prior Court of Appeal decisions (see, e.g., In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922]; In re Taya C. (1991) 2 Cal.App.4th 1 [ 2 Cal.Rptr.2d 810]; In re Rebecca H. (1991) 227 Cal.App.3d 825 [ 278 Cal.Rptr. 185]) and, in my view, properly effectuates the legislative intent in enacting section 366.26(k). I fear that the majority's contrary interpretation of the statute will thwart the overall legislative objective — evident in the numerous recent statutory reforms in the dependency area — of minimizing the delay inherent in the process of implementing a permanent plan for the placement of dependent children.

Upon respondent's motion to limit the scope of appeal, this court determined that the review efforts which were the subject of the motion could not be challenged following the selection and implementation hearing. Following In re Taya C. (1991) 2 Cal.App.4th 1 [ 2 Cal.Rptr.2d 810] and In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922], we ruled that review of interim orders made at review or reference hearings must be undertaken by timely writ petition and cannot be achieved as part of an appeal from a selection and implementation hearing judgment. We therefore issued an order limiting the scope of appeal.

This court held ( In re Brittany S. (1993) 17 Cal.App.4th 1399 [22 Cal.Rptr. 50]) it meant referral orders were not immediately appealable but were subject to review on appeal from the subsequent judgment pursuant to section 366.26 Other appellate courts held referral orders were not reviewable on appeal at all; the only way to get review was by petition for extraordinary writ. (See, e.g., In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922]; In re Taya C. (1991) 2 Cal.App.4th 1 [ 2 Cal.Rptr.2d 810].) These courts held that to rule otherwise would contravene the clear legislative intent to expedite finality in dependency proceedings, as evidenced by the streamlining of the entire statutory scheme that created the section 366.26 hearing.

(1b) Until recently, many courts construed this statutory exception to appealability as meaning that issues going to the setting of a section 366.26 hearing simply were not cognizable on appeal — not even on a later appeal from an order entered at the conclusion of the section 366.26 hearing. Such issues could be raised only by petition for extraordinary writ. (E.g., In re Tammy H. (1992) 11 Cal.App.4th 48, 51-52 [ 14 Cal.Rptr.2d 16]; In re Amanda B. (1992) 3 Cal.App.4th 935, 940-941 [ 4 Cal.Rptr.2d 922].) These holdings, however, were effectively overruled in In re Matthew C., supra, 6 Cal.4th 386.

In accordance with established precedent from the Courts of Appeal (see, e.g., In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922]; In re Taya C. (1991) 2 Cal.App.4th 1 [ 2 Cal.Rptr.2d 810]; In re Rebecca H. (1991) 227 Cal.App.3d 825 [ 278 Cal.Rptr. 185]) we would have dismissed this portion of the appeal as violative of the requirement of section 366.26, subdivision (k) that review of orders terminating reunification and referring for a section 366.26 hearing may be achieved only by writ review. The majority of the Supreme Court, however, in In re Matthew C. (1993) 6 Cal.4th 386 [ 24 Cal.Rptr.2d 765, 862 P.2d 765], ruled that failure to seek writ review after a section 366.21 or 366.22 order does not preclude later appeal following the judgment rendered after the section 366.26 hearing.

We note that the appellate decisions now final on this issue are in conflict. In re Amanda B. (1992) 3 Cal.App.4th 935 [ 4 Cal.Rptr.2d 922], In re Amber U. (1992) 3 Cal.App.4th 871 [ 4 Cal.Rptr.2d 726], and In re Cory M. (1992) 2 Cal.App.4th 935 [ 3 Cal.Rptr.2d 627], hold that challenges to orders made at review hearings are not appealable. [*] See 5 Cal.4th 242 for Supreme Court opinion.