Going smaller - from 225cc to 160cc. Should this be done in one or two procedures?

I have 225cc dual plane, need to replace and want to go smaller to around 160cc. - I had four consultations with different plastic surgeons: 2 say this is difficult and should be in two steps as the implant may rotate. 2 say this works. - I am confused. The ones that said this works did not see any problems. What is your experience? Do it in 1 or 2 steps?