With the coming age of very light jets (or whatever you want to call them) just around the corner, the question has been repeatedly raised but never really answered: How will pilots fare when transitioning from piston-powered airplanes to this new breed of little jets? It's a much more complicated question than it at first appears, so to come up with an answer, or at least to understand the question much better, we decided to conduct an experiment. Instead of wildly speculating (as much fun as that can be), we decided to take a typical very light jet pilot candidate and go out and do some actual flying. As luck would have it, I was the guinea pig for this assignment. In terms of my aviation experience and habits, I'm exactly the kind of pilot that safety experts have in mind when they worriedly bring up the issue of newbies flying VLJs into the flight levels. I'm a 1,200-hour non-multi-engine rated pilot who has quite a few hours in the latest high-performance technologically advanced singles. And my typical mission profile is strikingly similar to this new breed of pilots who will be transitioning en masse to VLJs, in that I fly almost solely for transportation, I file IFR on just about every trip, and I'm not only comfortable with new technology, I actively embrace it. Like a lot of our readers, I've also been dreaming about flying jets since I was a kid. Using me as the test subject, the specific question we looked to answer was this: Can a regular piston-single type pilot who flies IFR in the system and is reasonably proficient on instruments transition to jets? We'd find out. Of course, there aren't any VLJs yet. So we did the next best thing (actually, it wound up being even better than that) by picking a jet that emphasizes all of the challenges pilots will find when transitioning to turbofans. To conduct the test, we got together with John and Martha King, owners of King Schools and operators of a Falcon 10 business jet. At first blush, the Falcon 10 may seem like exactly the wrong jet for our purposes. Unlike VLJs, the Falcon 10 is very fast (.87 Mach), plus it weighs around three times as much as most of the VLJs (nearly 20,000 pounds full of fuel and people). And with its sweptback wings and leading edge slats, it has more in common aerodynamically with a Boeing 747 than with an Eclipse 500. But it's precisely because of these big-jet characteristics that the 10 is a perfect candidate for the job. If there's a challenge in flying jets, it's to be found in the Falcon 10. Before we got started, I spoke with John and Martha about the program, and we formulated what sounded like a reasonable plan. Before arriving in their hometown of San Diego, I'd prepare by studying up on the Falcon 10-I used SimuFlite's excellent flight manual for the airplane-and by going through a trio of online courses taught by King Schools: Jet Transition; High Altitude Flight; and Reduced Vertical Separation Minimums (RVSM). Then once I was in California, we'd spend an afternoon going over systems and getting to know the actual airplane before going flying the next day. The modest goal of the flying, as John King defined it, was to get to the point where I felt I would be able to "fly a jet comfortably with further training." I took that to mean, getting to the point that I would no longer be completely demoralized by the experience. Now, to be fair, I had a bit of a head start on my jet training. I've had the chance on a couple of occasions to fly in Level D jet simulators, so the jet experience wasn't completely foreign to me. I knew the feeling of handling the controls and watching the displays. But on those occasions, I was never doing any official training, and the instructor/pilots were always very helpful with the visiting journalist, so my official duties in the "cockpit" were limited. The instructor could even control the weather. The game plan with the Kings was to fly in a real jet in the real world.
Getting Ready Before I left for San Diego, I cracked open the flight manual. It wasn't an in-depth course of study by any stretch, but I wanted to familiarize myself with the basic systems and operation of the Falcon 10 so the airplane wouldn't be a complete mystery to me when I arrived. I spent about a day going over the systems and the standard and emergency operating procedures. It would wind up being a big help. There are a lot of things about jets that pilots who fly piston-powered airplanes never learn simply because their world doesn't involve those things. When climbing through 18,000 feet, for instance, you change over from the local altimeter setting to a standard setting, 29.92, or vice versa when descending back through 18,000 feet, not something I ever need to worry about in my Cherokee Six. Neither do I worry my pretty little head about when to change over from reading my indicated airspeed in knots to reading it in Mach speed. It's just not an issue for me. But these types of things are part of the fabric of daily operations when you fly jets, and inattention to them is a bad thing. Luckily, the Kings' Jet Transition course is designed with pilots like me in mind. The course, which took me about four hours to complete, covers all of the big background questions about jets: Why do they fly so high? What's up with turbine engines? Are all jets alike? What's the guaranteed takeoff performance in jets? and Who does what in a crewed cockpit (one that has both a pilot and a copilot)? A lot of these questions might sound silly to those already well versed in jets, but that's precisely the point. The big, overview questions are exactly what pilots looking to transition never get answered. In traditional courses, that kind of information just kind of filters down through the noise of the details. Not so with the Kings' Jet Transition Course, which tackles those questions head on. "It's designed to teach things an experienced good friend would tell you to make the transition to jets easier," said John, who explained that neither he nor Martha had the advantage of such a course when they made the leap to jets years ago. Like everybody else, they had to figure things out on the fly. Over the weekend before my trip to the Kings' I also completed the two other ground courses, RVSM certification(which took about an hour to complete) and the High Altitude Endorsement Ground Training course (about three hours). In keeping with my theme of thinking I knew more about jets than I really did, both courses were eye-openers for me, answering questions that I'd had for years about such topics and bringing up subjects I'd never previously considered. As it would turn out, the three courses were invaluable preparation in my quest to transition to jets, because they kept me from asking all of those questions once it was time to get into the airplane, where, I'd soon learn, there would be more than enough to do. Nerves As I was preparing for the course, I developed a real case of nerves, and it was mostly because of the tiller. A tiller is a small ground steering wheel located on the left side of the captain's seat (the left seat), and I'd discovered in my going over the flight manual that the Falcon has one. There's just one, so if you're in the left seat, it's all on you. The tiller setup varies from airplane to airplane. In the Falcon 10, you use the tiller to taxi the airplane and also on the takeoff roll until you get up to 80 knots. Up until that point, the captain doesn't even have the yoke in his hand-the right hand is on the throttle and the left hand is on the tiller-so there you are, hurtling down the runway controlling the airplane with a notoriously sensitive little dial on the sidewall. The good news: At 80 knots, you move your hand from the tiller to the yoke, and things go back to normal again for a few fleeting seconds before you rotate. (The better news: None of the new VLJs have a tiller.) My case of jitters wasn't helped by the story John told me about how he and Martha volunteered to help out a Falcon 10 sim instructor who needed to get some time in the real airplane. On his first few attempts, he was all over the runway trying to keep things under control. Great, I thought. If the sim instructor can't control the thing, what chance did I have? The afternoon before we were to go flying, John and I went out to pay a get-to-know-you visit with the jet. We started our orientation with a walk-around, paying special attention to the things that make jets different from piston airplanes. We looked at the sweepback of the wing, the leading edge slats, of course the engines, the tail with its trimmable stabilizer, and the heated windshield, to name just a few of the very different kinds of components you find on jets. Then we boarded the airplane. There are stories, probably not apocryphal, of sim-trained jet pilots getting to the airplane and not knowing how to open the door, the sim, of course, not having a door. We climbed into the cockpit to get acclimated. The Falcon, like every jet of its era, has a host of knobs, switches, buttons, lights, warning horns, levers, dials, breakers, gauges and displays. Although the Falcon's panel is more intuitively laid out than most, there's still a lot to get to know, let alone master. To familiarize me with the panel (and sub-panels, and overhead panels), we simply ran the checklist. It took us an hour and a half. Granted, much of the time was spent with John explaining things to me, like the logic of the hydraulic checks (please, no pop quiz on this one), so going through the checklist in real life would take much less time. That said, it can still take a well-trained crew of two 20 minutes to run the first check of the day. A cursory walk-around the airplane and a quick CIGARS check heading out to the runway? It's not a good plan when it comes to jets. There are simply too many things to check. In fact, I came to realize that is one of the primary things that differentiates jets from the light stuff, the overall complexity of the flying chore and the commitment to professionalism required of the crew (even if you're a crew of one).
Getting AirborneAfter breakfast the next day we went flying. The plan was for Martha, who was acting as captain, and John, who was flying as first officer, to fly the first leg, from San Diego's Montgomery Field to Blythe, near the California/Arizona border, where I would take over, eventually flying us all the way back to my home airport in Austin, Texas, a thousand miles away. There were two compelling reasons for Martha and John to fly the first leg. First, it would give me a chance to observe the process from the side-facing seat right behind the cockpit, and because the airspace around San Diego is extremely busy, and I wouldn't need additional challenges. If you've ever watched a professional flight crew in action in a high workload environment, you know it's an impressive sight. Sitting in the jump seat going out of Montgomery Field (elevation 427, runway length 4,600 available for takeoff, 3,400 for landing), I watched with special interest since it was going to be me in the left seat on the next leg of our flight. What interested me most was the dance of hands that transpired on the takeoff roll, with Martha advancing the throttles, steering via the tiller as we accelerated like a rocket down the runway. John as copilot made the callouts: "80 knots." Martha's hand came off the tiller and she called out, "My yoke." "V1," John called out at 107 knots. Martha's hand came off the throttles and took the yoke in two hands. "Rotate," John chimed in as we reached 114 knots, and Martha briskly rotated the Falcon to 16 degrees nose up. "Positive rate," John chimed in. "Gear up," commanded Martha. John raised the big red lever, and the 10 left Montgomery Field far below as it rocketed upward at 4,000 fpm. And the enthralling performance continued. Just watching Martha and John working together was a real education in what it takes to fly jets. Compared with flying my Six, the SR22 or any other single I've ever flown, the differences are dramatic. With jet speeds, time itself is compressed. You simply don't have 10 or 15 seconds to think about things before you do them; you've got to respond, like right now. If you don't, you can bust the 200-knot speed limit in the Class D or the 250-knot limit below 10,000 feet, or worse, much worse. Also, the teamwork needed to fly a crewed jet is something that can only be accomplished through rigorous and regular training. While this kind of teamwork won't necessarily be required in VLJs, all of which (to our knowledge) will be authorized for single-pilot operation, all or nearly all of the steps it takes to fly the Falcon will need to be performed by the single pilot of any VLJ. Those pilots will be kept very busy, to be sure.
After landing in quiet Blythe (CA), Martha and I switched seats. I'll spare you the amusing details of my trying to master the tiller steering, but suffice it to say that by the time I'd repositioned the airplane to the takeoff end of the runway John felt confident in my ability to keep the jet rolling relatively straight on takeoff. That made one of us. My first takeoff was no work of art. As best as I remember-for some reason I wasn't taking notes at the time-John had to remind me to take my hand off the tiller and he had to physically move my hand off the throttle at V1. I did rotate to the recommended 16-degree climb attitude (a horrifyingly big number to those of us who fly light singles), but I was late in getting the power back to 90 percent N1 and I promptly blasted through the pattern altitude at Blythe. Two more big differences: As I mentioned, you set power in a jet by reference to N1, or fan speed. Different jets have different engine control systems, and the Falcon has a kind of fadec-lite that makes management much easier. Most VLJs will have fully automated power controls. Also, and probably more importantly, I quickly learned that flying a jet is not an out-the-window experience. In order to fly with the precision required to keep the slippery airframe where you want and at the proper speed, you pretty much need to be on the gauges full time. The concept of see-and-avoid is tough to reconcile with single-pilot operations in jets. So pilots looking to transition who aren't comfortable flying by the numbers will be in for a challenge. Another big challenge facing piston pilots looking to make the leap is the flight director. I have to admit that I never truly understood the need for the instrument until I flew in the Falcon. In order to fly with any semblance of precision, you need to constantly monitor the changing state of the flight path. Unlike in a slow and draggy piston airplane, doing that by hand and eye alone is nearly impossible. The flight director, which can respond more quickly than the human eye to trend changes, makes precision flying possible. The aerodynamic challenges to the transitioning pilot are found in two dramatically different phases of flight: landing and cruise. John and Martha had separately warned me that one area where would-be jet pilots frequently stumble is making good approaches and landings. The problem is, the way our piston airplanes, and their engines, operate is fundamentally different than the way jets do. Because they're intended to go fast, jets have highly-loaded wings. (Sweptback wings, like on the Falcon, present new issues altogether, though since the VLJs are straight-winged craft, I won't go into the details here.) Get slow on final in a jet and two big problems present themselves. A heavy, draggy airplane that gets too slow will sink like a stone. Of course, the best way to counteract that tendency is to not let it happen in the first place, which means keeping a close eye on your reference speed (calculated for each new landing) and simply not letting it happen. The problem is, if you do start to sink when the engines are already at flight idle, you might have to wait a while-John says it can be as long as eight seconds in the Falcon-after increasing power for the engines to spool up. Until they do, all you can do is wait. Also, as you approach in a jet, you're going a good deal faster than you are in a piston single (though some of the VLJs will come over the fence at piston twin speed). The technique is to closely monitor the instruments, especially airspeed and VSI, before transitioning to a visual landing after the runway is made. It's very much like an instrument approach on every landing. The result is a very different view of the runway, leading most transitioning pilots to flare too high, something I was certain I would fall victim to but didn't, probably because of the wisdom imparted by the Kings in the Jet Transition Course I'd just completed a few days prior. Based in part on my own experiences, I think that making stabilized approaches will be a difficult, and potentially riskier, skill for transitioning pilots to develop, while learning to land consistently will be an easier task to master, as long as the pilot's speed control is good. Helping matters is the fact that, unlike piston-powered airplanes, most jets approach in a slightly nose-up, landing-ready attitude, and once they're ready to touch down, they normally do so without much float. High altitude also presents challenges and poses risks in terms of oxygen, or the lack thereof, to be more precise. Dealing with pressurization is a surprisingly straightforward thing, though tremendous care needs to be taken in the preflight phase to avoid unexpected surprises of the worst kind. As part of my high altitude endorsement training, we conducted a simulated emergency descent, the kind you'd make in case of a real depressurization. The good news is, these airplanes can get down to breathable altitudes in a hurry. The bad news: At 40,000 feet, you might have just 10 seconds of consciousness before you get your oxygen mask on. Intimate knowledge of emergency procedures-there's no time to use the checklist-is the only thing that will keep you and your passengers alive in such an instance. After our simulated emergency descent, we landed at Las Cruces, New Mexico and had a bite to eat at the great little airport restaurant before climbing back into the 10 and heading on to Austin. The last leg went smoothly, and before you know it, we were a couple hundred miles out and ready to descend.
And there was another big difference between jets and light airplanes. With 280 miles left to go in an SR22, let's say, I'd be checking what was on XM radio to wile away the time. In the Falcon 10 (admittedly a faster airplane than any VLJ), we had a half-hour to start down, make our 10,000-foot crossing altitude at Llano and begin the arrival. In a jet, you simply need to prepare ahead of time, and careful descent management is critical in order to keep from being either too high when you arrive or low too soon, which wastes valuable fuel. The controller vectored us over the city of Austin and then towards a long left base for Runway 35R. We had the ILS dialed in, and as I hand-flew the approach I couldn't help but feel a touch of pride in arriving at my home airport in such high style, and with me flying nonetheless. Looking Ahead At dinner that night John and Martha and I discussed the experience and what we'd learned from it. The big question we began with was, "Can a regular piston-single type pilot who flies IFR in the system and is reasonably proficient on instruments transition to jets?" The answer was, "Yes." I had some real advantages, to be sure, including a pair of excellent instructors who had gone through the same process as I was starting out on and who had come back with some good advice on how to make the transition work. But I also came away with a strong conviction that this transition isn't for every pilot. It's not even for every pilot who wants to and can afford to make the jump. Flying in the flight levels requires a serious commitment of time and energy. You've got to know the airplane inside and out, backwards and forwards, and you've got to spend the time learning to fly it well, and that commitment doesn't end with a type rating. You've got to train regularly in order to keep flying it well. While jets in general provide a tremendous amount of reserve performance compared with piston singles and twins, and a great deal of redundancy, their margins of safety can be small. Moreover, they require precise and consistent performance to get that added safety out of them. I learned firsthand that the rewards of flying a jet-speed, altitude and safety-are tremendous things, but so are the challenges. For those pilots who are up to the task, who are willing to put in the time and the effort to hone their skills and know their platform, the thrill of a lifetime awaits. ** THE END But check out additional materials on the following pages.**
John and Martha King: Teachers and Pilots To say that the Kings are an unusual aviation couple is an understatement. They founded, own and operate King Schools, a business that produces aviation educational materials designed to do just two things: Help pilots pass their FAA knowledge tests and make us all safer fliers. Over the past 30 years, tens of thousands of pilots have used the Kings' products, and the school has developed courses of study for Cessna, the FAA, and even Microsoft. But purely in piloting terms, the Kings' achievements are just as remarkable. Both John and Martha have every aircraft pilot certificate-they each recently added their powered parachute tickets-they're active instructors, and they regularly and enthusiastically tackle new challenges. Last year they flew their Falcon around the world. When it comes to jets, they're not just remarkable; they're likely one of a kind. As far as we know, they're the only married couple who crews their own bizjet, swapping turns in the left and right seats. For years, the Kings flew a Citation 500, and a few years back when they decided to look for a new challenge, they gravitated to the Falcon 10, an airplane that offers up tremendous speed while requiring top-notch piloting skills, thanks to its big-airplane systems and flying characteristics. As far as VLJs are concerned, the Kings, though they love the concept, aren't in the market. They're pretty happy with .87 Mach and a 1,500-nm range, figures you won't find in anything that incorporates the word "light."
Is the Falcon 10 a VLJ? Not even close! The airplane I flew for this story, the Dassault Falcon 10, isn't a Very Light Jet, not even close. The airplane was developed in the 1970s to compete with Learjets at the then-low end of the market. More expensive to own and to maintain, the Falcon 10 (and later the avionics-upgraded Falcon 100) couldn't compete with the Lear in the marketplace, even though the French airplane was faster and had better handling qualities. Only about 250 10/100s were built. Of those, about 180 are flying in the United States today. While it's the smallest Falcon, it's not a small airplane. The Falcon 10 weighs more than 19,300 pounds fully loaded, and its MMO (max mach operating speed) of .87 Mach made it about the fastest bizjet in the sky until the Citation X came along a few years ago. The 10 requires a crew of two, as opposed to most VLJs, which will be single-pilot capable. Equipment wise, the Falcon has a lot of big-airplane equipment, including leading edge slats, airbrakes, bleed air de-icing, hydraulic controls with artificial feel, anti-lock brakes, and a tiller for steering the airplane on the ground. What it does have in common with VLJs is that it's a personal-sized bizjet that's flown alongside airliners in the high-20s through the 30s. If you're up for the flying challenges, and the maintenance costs, a nicely equipped used Falcon 10 can be had for between $1 and $2 million, less than the projected cost of most VLJs. Want to learn more about flying jets? Check out the courses that I took online through King Schools as I was preparing for my flying with John and Martha. King Schools Online
Making the Transition to Jets: An Instructor's View By John King Robert dramatically demonstrated that a good instrument pilot, well prepared, can transition into a jet smoothly and learn very rapidly. Working with Robert in his transition to a jet in our Falcon 10 was one of the most rewarding flight instructing experiences I have ever had. A flight instructor has the privilege of sharing very special life-defining events with students. I knew for sure that Robert would remember this day in vivid detail for the rest of his life. He will never forget how his right hand controlled those jet engines with the unfamiliar whine coming from behind instead of in front, and the great, smooth surge of power delivered like magic with no propeller in sight.
The day was a resounding success in most part because Robert was the perfect student. He is a current, highly competent pilot and very proficient on instruments. Plus, he was splendidly prepared. He had thoroughly studied the material on the systems of the aircraft that I had sent him, and had taken our online jet transition course designed to pass along all the practical tips that Martha and I would want to share with a good friend transitioning into jets for the first time. Robert's training with me began the night before in the cockpit of the airplane while on the ground. We spent a couple of hours using the cockpit as a procedures trainer and going over all of the controls. By the time we were done, he had the checklists down for each phase of flight.
Robert's first flight in the airplane was as an observer while Martha as captain and I as copilot demonstrated what a normal flight should look like. This gave Robert the opportunity to observe the pitch attitudes and power settings. It also gave us the opportunity to re-position the aircraft to Blythe, California, where we would have less busy airspace and more room to maneuver.
At Blythe Martha moved out of the captain's seat and Robert moved in. Martha sat behind us to make sure we stayed out of trouble.
We chose Blythe because I wanted Robert to do his first trip around the pattern at a place where altitude control was not critically important. I had observed in the past that pilots not used to the climb performance of a jet have a hard time leveling off at the target altitude on the first takeoff. Plus, there is a tendency to be a little intimidated by flying a jet, and it makes pilots reluctant to be aggressive about controlling the airplane. Robert was no exception. We overshot our pattern altitude by 600 or 700 feet.
Pilots new to a jet also have difficulty with the pitch and roll sensitivity, and Robert demonstrated that by altitude excursions of plus or minus 300 feet and wing rocking on downwind. All of this is just part of the process of getting calibrated to a more sensitive airplane. At first you just don't know how much control pressure to use. The amazing thing is that by the time we turned base, Robert had the control pressures figured out and we were steady on altitude and heading.
It was on final that Robert's preparation and skill as a pilot came into play. Most new jet pilots have a very hard time with speed and altitude control on final because without propellers you don't get the blast of air over the wings when you increase power. In a jet, to get more air over the wings, you have to accelerate the whole airplane. Also, with props, when you need to slow down, the propellers will turn into great big airbrakes. Jet engines, on the other hand, continue to provide residual thrust even at idle.
So I was expecting to see Robert have the normal speed excursions that everyone else has. He didn't. I had told him that in landing configuration in the Falcon he would need a slight nose-up pitch attitude and a power setting of about 68 percent of fan speed, and to make minor adjustments as needed. Robert dialed those in and we went down final like we were on a rail. I think the online jet transition course might have helped him out on this, or it may be that he is just a naturally smooth pilot.
Also, I had told Robert that he really had only three things to worry about-heading, altitude, and airspeed. If he did a good job of those, I, as his copilot, would take care of everything else, and he would do just fine. Well, he did just fine. On the landing new jet pilots tend to get a speed rush and flare too high. Not only that, but the proper landing technique for a piston airplane of holding the airplane off until it touches in a near stall attitude just won't work in a jet. The residual thrust of a jet and the clean aerodynamic design would mean you could float the whole length of the runway. The proper technique for a jet is to arrest the descent, hold the pitch attitude, and let it touch.
I was expecting Robert to follow the piston-pilot pattern and instructed him to not flare until I told him to arrest the descent. I overcompensated for the normal tendency to flare too soon and was too late in telling Robert to arrest the descent. He did exactly what I told him to do and we got a little skip on the first landing. On every landing after that I kept my mouth shut and he got progressively better and better until on the last landing the wheels just started rolling. I was still asking him if we had touched down yet as he taxied off the runway.
After three trips in the pattern at Blythe, we picked up our IFR flight plan to Las Cruces, NM. Robert was in complete and smooth control. While the airplane was on autopilot at altitude, we briefed the arrival into Las Cruces and the ILS approach. Also, we were going to do a simulated rapid decompression and emergency descent into Las Cruces so Robert could get his high altitude endorsement, and we briefed those too.
The emergency descent follows a checklist that requires the crew to put on oxygen masks, re-establish communications with each other, bring the throttles to idle, deploy airbrakes, roll into a forty-five degree bank, and pitch down to redline airspeed. The result is you are staring at the ground while descending at better than 8,000 feet per minute. It is a very impressive view out the front window. The first time, everybody has trouble keeping the nose down enough to get redline airspeed. Robert came down at a speed a little short of redline, but not bad for the first time, and well within the acceptable range.
After lunch, the next leg was from Las Cruces to Austin, Texas. Robert flew the leg flawlessly, including the ILS into Austin. I told Robert that Martha and I would be comfortable hiring him as a copilot at the skill level he displayed. But Martha said that she already has a copilot and doesn't need another.
Is it clear that Robert can fly a jet? You bet. In one day of flying he developed the basic control of the aircraft required of a jet pilot. Is he ready to be pilot-in-command? Not yet, but he's not far off. We kept his workload down so that he could concentrate on basic control. The next phase of his training would be to give him more complexity to deal with by having him fly in more dense airspace and giving him some systems problems to solve. But he is ready for that challenge. How will the pilots transitioning to very light jets do? If they are as well prepared as Robert, probably just as well as he did. The greatest concern a lot of folks have is the question of whether there will be a jump in the turbine accident rate when we get this crop of new turbine pilots. In my view there probably will be, but these new pilots will probably be safer than they would have been in piston twins-just not as safe as the current turbine fleet.
I don't think the problem will be basic aircraft control. Robert demonstrated that piston pilots can transition to a jet very quickly and do a fine job of controlling it. The problem is that these new pilots are likely to come into turbine aircraft with a different mind-set than the current professional turbine pilot. These folks will often be entrepreneurs with a desire to prove how capable they and their airplanes are. They will face a new set of risks without the seasoning afforded most turbine pilots by years spent as a copilot.
We need to figure out how to make these new jet pilots aware that especially in a jet their number one priority is risk management, and give them the tools to manage those new risks.