We address the mechanisms underlying zonal Row generation and stability in
turbulent systems driven by the electrostatic ion-temperature-gradient (ITG
) mode. In the case of zonal flow stability, we show the poloidal flows typ
ical of numerical simulations become unstable when they exceed a critical l
evel. Near marginal stability of the linear ITC mode, the system can genera
te zonal Rows that are sufficiently weak to remain stable and sufficiently
strong to suppress the Linear ITG mode. This stable region corresponds to t
he parameter regime of the nonlinear Dimits up-shift.