Factors governing the development of cellularity in orographic precipitation are investigated. These factors include the moist static stability, the residence time of air parcels within the saturated region over the upwind slope, the depth of the upslope cloud layer, the amplitude of short-wavelength terrain induced perturbations and the environmental wind shear. Simplified theoretical analysis is combined with idealized two-dimensional numerical modeling to analyze and illustrate the sensitivity of the cellularity to variations in these factors.