Risk 1: 1,400 programs x 2,000 average LOC = 2.8 million lines. Industry data suggests COBOL-to-Java conversion at 10-20 LOC/hour when accounting for testing and business rule validation. At 15 LOC/hr, that is 187,000 person-hours or ~90 person-years. With a team of 20 developers, that is 4.5 years,