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The nonlinear statistical growth rate eq for convective cells driven by drift-wave (DW) interactions is studied with the aid of a covariant Hamiltonian formalism for the gyrofluid nonlinearities. A statistical energy theorem is proven that relates eq to a second functional tensor derivative of the DW energy. This generalizes to a wide class of systems of coupled partial differential equations a previous result for scalar dynamics. Applications to (i) electrostatic ion-temperature-gradient-driven modes at small ion temperature, and (ii) weakly electromagnetic collisional DW's are noted

Hamiltonian Description of Convective-cell Generation