The vertical energy flux of unstable planetary-scale waves in a statically stable atmosphere is shown to decrease at least exponentially with increase in altitude in a layer containing neither horizontal or vertical shear in the mean zonal wind. An infinite layer containing a uniform zonal wind, superimposed upon a lower layer containing vertical shear, will thus completely trap the energy of unstable waves generated in the lower layer.
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Charney et al. (1963) studied this question.
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