In the past 5 years, further advances in resolution has resulted in 1 to 3 km convection allowing NWP which enable forecasters the ability to anticipate the location of the heaviest rainfall down to a basin level. While these improvements are significant, at times it has been discovered that in certain orographic enhanced forcing environments the new NWP may grossly over-estimate precipitation. This study will focus on particular events when apparent over production in precipitation was generated in shallow low-level boundary layers and orographic flow. It was apparent the instability present in these atmospheric conditions were a mixture of warm and cold air precipitation processes that may yield QPF error due to inherent issues of properly resolving microphysics, and the inability to effectively reduce the instability in the orographic forcing which may limit precipitation duration and amount.