https://www.aamc.org/students/download/267622/data/mcatstudentselectionguide.pdf
Let's also qualify for a second here what "Greater" risk for failing step 1 actually means. 83% of people with a 3.8+ and 21-23 passed Step 1 on their first attempt. Number goes up to 90% for those with 24-26's. National average is 94%. So when we talk about being a greater risk we are basically saying OP is about 5-10% more likely to fail step 1 on their first attempt than the average applicant. Now for the risk adverse nature of ADCOMs, that 5-10% additional risk is a lot. But in the grand scheme of things, odds are still strongly in favor of someone like this passing Step 1 the first tiem.
Now the better argument to make here is that ADCOMs don't merely want people who can just pass Step 1. They want people who can excel. That's where the OP's problem is when presenting a case to medical schools about why they should be accepted. Because if we are being honest, the odds of a 2.6 GPA student with a 22 MCAT being able to graduate an MD school in 5 years and getting a residency and being a physician are still more favorable than not.
Having said that, as much as we don't like to admit it there are numerous people with 23's and 24's accepted to newer DO programs every year, many of whom don't have close to a 3.9.