Let , , and use . The uniform upper-layer flow over a resting lower layer has the dispersion relation
Its discriminant is . A negative value gives exponential baroclinic instability. This model includes advection across the interface-induced potential-vorticity gradients in a meridional two-layer current.
For purely meridional wavevectors, , , the growth rate of a uniform meridional upper-layer flow over a resting lower layer is
Growth requires and . The perturbation has no northward velocity, so planetary vorticity advection does not explicitly stabilize it. At fixed normalized wind stress curl, means stronger nevertheless reduces the shear and growth rate.

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