Second, a viable plan presents the common goals, purposes, values, principles and norms that underlie and support it in order to ensure consistency of vision and purpose. It spells out as early on as possible what the planners are attempting to achieve through their plan. The overarching values underlying state planning in Ohio are: (1) the creation of a legal services delivery system that provides comprehensive, integrated high quality legal services to the client community and (2) "100% access to essential legal services for low-income Ohioans such that they are able to secure substantive and procedural equal justice". The planning steering committee and the program directors in Ohio adopted the principles outlined in the document on state planning prepared by the Project for the Future of Equal Justice.

Third, a defensible plan is one that has been discussed with and/or reviewed by individuals, organizations and institutions within the state that have a stake in the design and operation of the state's system for ensuring equal justice. We understand that numerous stakeholders were given the opportunity to comment upon this plan and that the planners will involve other internal and external stakeholders in the planning process as you move forward to refine and implement the plan.

Fourth, a good plan presents its goals both in terms of their measurability and in terms of who is responsible for ensuring their completion. Responsibility is either assumed or assigned. Perhaps more importantly, responsibility is shared between and among everyone who is covered by and included in the plan. In this plan, it is clear that the Ohio Legal Assistance Foundation (OLAF) and Ohio State Legal Services Association (OSLSA) assume significant responsibility for implementing many sections of this plan. However, we were very much impressed with the fact that legal services providers and their staff throughout the state also play a significant role in implementing provisions of this plan. The plan demonstrates that OLAF, OSLSA, and the individual legal services programs are committed to implementing and evaluating this plan. We would recommend, however, that you give serious thought to assigning to a specific member of the steering committee the responsibility to coordinate and manage the implementation of the plan.

Fifth, in order for a plan to be considered effective, the plan must demonstrate that all of the legal services providers were willing to look beyond single issues or a single program to examine the big picture in terms of client needs and organizational capacities in order to develop the best possible methods and mechanisms to address the present and future needs of clients within the state. A good plan for the statewide coordination of legal services presents concrete information as to what the legal services providers believe to be the major issues confronting clients and the client communities served by the programs, indicates how the programs can work collaboratively to respond to these issues, and spells out what the legal services programs envision for their collective future and for the future of their delivery system.

This plan presents concrete information as to what the legal services providers believe to be the major issues confronting clients and the client communities served by the programs. It clearly demonstrates that the planners are seriously committed to developing the best possible methods and mechanisms to address the present and future needs of clients within the state. Plans for significant systemic changes are clearly placed on the table.

Sixth, a defensible plan will fully respond to all of the issues identified in LSC Program Letters 98-1 and 98-6. This plan fully responds to LSC concerns.

The report describes in detail Ohio's commitment to client empowerment, client and community education and the expansion of pro se options. The plan includes an impressive description of what is currently going on in the area of pro se advocacy within some of the programs and describes two initiatives that the state will pursue to increase the quantity and quality of pro se assistance. These include an already-approved and funded "Pro Se Project" coordinated by OSLSA and funded by OLAF and the Ohio State Bar Foundation to develop standardized pro se materials for use across the state, set up two pro se pilot projects in rural Ohio and develop training materials for pro se clinics. Another proposed project that the state is considering will develop software for pro se advocacy by victims of domestic violence and then install computers with the applicable software in several domestic violence shelters in Ohio to test out how effective the approach is.

Coordination of Legal Work---Legal work is coordinated through OSLSA and through the emerging Litigation Director's Task Force (which was created during the planning process). The task force has two initial goals: (1) prioritize, coordinate and develop a work plan for legal work on a state-wide and regional level; and (2) develop resources to support this legal work through pooled resources of programs, through collaborations with law schools, through special funding from OLAF and foundations, and through the creation of additional task forces.

Specific Collaborative ProjectsCThree initial (new) projects were identified during the planning process and the OLAF evaluation process: the development of statewide practice standards by fall 2000; the development of additional mechanisms for consultation and support by substantive law experts; and the expansion of technology to support advocates including but not limited to the creation of an electronic brief bank and a secure chat room allowing for confidential consultations on cases and matters.

Training and Task Force CoordinationCOhio has a long history of providing a wide-range of high quality training through CORT, OSLSA, and the Ohio Continuing Legal Education Institute. OSLSA recently reinstituted a statewide training advisory group and coordinates substantive task forces and work groups. OSLSA also functions as the state's information clearinghouse.

This report ranks resource development as a very high priority and Ohio legal services providers have historically collaborated--most recently under the leadership of the Ohio Legal Assistance Foundation--on very successful and impressive fund-raising endeavors. Ohio's legal services programs are fortunate to have multiple sources for funding in addition to the LSC funds. IOLTA funding for legal services in Ohio was $8.8 million in 1998 (OLAF has significantly increased IOLTA dollars through a number of initiatives). Projected filing fee income is approximately $6.2 million annually. $375,000 comes from attorney registration fees and is currently committed to pro bono enhancement, technology development, and OLAF's program assessments. Private sources support, among other things, a statewide pro bono program aimed at providing services to SSI children, domestic violence projects, welfare to work projects, senior citizen projects, and housing advocacy work. OLAF works each year to try to generate general revenue funding.

OLAF has also played an important leadership role nationally in the effort to expand legal services' funding base.

Ohio proposes seven LSC service delivery areas complemented by statewide entities such as OSLSA and EJF and has requested that LSC proceed to redraw service area boundaries in April, 1999 for the year 2000. The service areas currently covered by SEOLS, Columbus and the Legal Aid Society of Cincinnati would remain as they are currently configured. In Northwest Ohio, Legal Services of Northwest Ohio would pick up all of Lucas County and one county currently served by Cleveland. The service areas now comprising Allen-Blackhoof, Rural and Dayton would be combined. Two new service areas would be created in northeast OhioCone would include Cleveland and the counties that border the lake and the other would be comprised of ten northeast counties including the cities of Akron and Youngstown.

The Legal Aid Society of Dayton was also involved in the discussions with ACBALSA and RLAS. The new rural program and Dayton have agreed to work diligently in the next three months to develop a comprehensive plan for the new service area. This agreement was finalized in late February, so discussions about details have just begun. Representatives of the three current programs are meeting to learn more about each other's current service delivery systems, staffing, and other salient factors to determine how the new service area can optimally be served. Particular service delivery techniques or approaches which are exceptionally well developed in one of the three current programs may be replicated or adopted for use throughout the whole service area. (For example, "tried and true" techniques to engage the private bar in pro bono efforts which are working well in part of the new service area may be expanded.) "New and improved" service delivery approaches for the entire service area may be adopted. (For example, a regional hotline may be implemented.) We will work to assure elimination of any unnecessary duplication and to guarantee delivery of high quality legal services and cost effective operations throughout the new service area.

Most recently, the Committee met and discussed proposed "Guiding Principles." The Guiding Principles were developed to help establish a framework for those areas where the organizations are in agreement. Most recently, the Toledo Legal Aid Society's Board of Trustees unanimously adopted these Guiding Principles. LSNO and ABLE 's Board of Trustees intend to meet in March or April of 1999 to consider them.

LSC Configuration Response

LSC has decided to approve the seven-region configuration proposed by the Ohio Planning Committee and ratified without dissent by all of the Ohio Project Directors. Further, LSC accepts the plans as outlined above with the following comments and/or exceptions:

Through its plans for regionalization we believe that the state of Ohio is taking important steps to build a better delivery network. We applaud the proposed program mergers in the West Central Region, Northwest and Northeast Lakeside Regions. We accept the offer of the West Central Region to provide us frequent progress reports as to the status of the merger discussions between and among the three programs (we are particularly interested in how the Dayton program will be combined with the other two programs) and ask that the Northwest and Northeast Lakeside Regions do the same. Status reports (short) should be sent to Randi Youells monthly. We suggest April 15,1999, May 15, 1999 and June 15, 1999. If you would prefer a different reporting date, please contact Randi Youells.

We are somewhat concerned about the language used in the March 16, 1999 letter sent by the Ohio Planning Steering Committee in response to a request from LSC which provided more detailed information on the program merger/consolidation plans for the seven proposed regions. For example, the second sentence of the second paragraph includes the "caveat that final decisions have not been made with respect to most issues in most areas." The last sentence of the second paragraph states as follows: "Please note that these are all subject to change as things develop". So that there is no confusion down the line, we would like to make LSC's position very clear. The Corporation has consistently made its position on the multiplicity and size of programs in Ohio clear. Our agreement to approve the seven-region configuration proposed by the Ohio Planning Committee is based upon our understanding that the legal services programs in Ohio are in the process of creating a new legal services delivery system that will reduce the number of providers within the state thus creating the potential for a highly integrated and coordinated delivery system. Further, it is our understanding that the merger/consolidation plans outlined earlier in this letter were developed and communicated to LSC in good faith and that barring unforeseen circumstances--which would be immediately communicated in writing to LSC--will be implemented in a timely manner.

We have serious concerns, based upon the information provided to us in your March 16, 1999 letter, as to the plans for the Central Northeast Region. It appears from reading the vague plans for the region as described above that the Central Northeast Region is preparing to create a consortium of the existing legal services program to develop and submit a proposal to LSC while retaining their separate identities. The minimum level of collaboration outlined for this region is not acceptable to LSC.

We would like to meet with the five programs currently involved in the creation of this new region and with representatives from the Ohio Planning Steering Committee (who are not members of this region) as soon as possible. We suggest that the meeting be convened for sometime during the week of April 12, 1999. Further, this region should provide Randi Youells a detailed status report concerning their activities and plans on May 15,1999 and June 15, 1999. (If you would prefer a different reporting date, please contact Randi Youells.)

We also suggest that the Ohio Planning Steering Committee designate one or more of its members (who are not members of this region) to monitor this region's plans for program consolidation. Further, we believe it would be in everyone's best interest if the Ohio Steering Committee developed contingency plans for this region in the event that the five current legal services programs designing a program to serve this new proposed service area are unable to reach agreement on program merger/consolidation and are consequently unable to develop a credible application to submit to LSC. One possible solution would be to combine this service area with the Northeast Lakeside region, with the region now served by SEOLS, or with the region designated as Central Ohio.

This plan effectively lays the groundwork for a comprehensive and integrated delivery system throughout the state of Ohio. This plan is impressive on its face and even more so given how much work Ohio did to get to this point. At some point in the planning process Ohio clearly focused its planning work on the question "what can we do to create the optimal legal services delivery system in Ohio" and the plan takes significant and measurable steps to make high quality legal services available to all low-income people in Ohio. We are confident that under the leadership of OLAF, OSLSA and the planning steering committee, this plan can be implemented in a timely and effective manner. Recognizing that the implementation phase of the planning cycle is often the most difficult phase, we suggest that you give serious thought to assigning to a specific member of the steering committee the responsibility to manage the implementation of the plan choosing someone who has prior experience with plan implementation. We also urge you to give immediate attention to the issues that face the proposed Central Northeast region as discussed above and closely monitor the proposed mergers within the remaining three new regions to ensure that everything proceeds smoothly and in a timely manner.