On May 10, 2011 the proposed decision by California Administrative Law Judge (ALJ) Maribeth A. Bushey was released. This tentative order would not allow California transmission operators to establish their MAOP for transmission pipelines in service before 1970 by identifying the highest actual operating pressure of the segment during the five-year period between July 1, 1965 and June 30, 1970. In addition, this order requires California natural gas transmission pipeline operators to prepare and file a Natural Gas Transmission Pipeline Comprehensive Pressure Testing Implementation Plan to replace or pressure test all natural gas transmission pipeline in California that has not been tested or for which reliable records are not available. While operators are developing their Implementation Plan, they will be required to abide by any pressure reductions that have been or may be ordered by the California PUC or PHMSA.