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I've seen some days with lows in the 20s (and even a few with lows in the teens ) where it rained at some point during the day. Just straight up rain, no snow, sleet or freezing rain.
This can sometimes happen when a warm front moves in the evening of a winter day, bringing a rapid warm up (wind shifting to west) and rain at the first start instead of snow.
So a cold start with a low of -10°C (14°F) in the morning can indeed be possible, while in the evening it can already up to 3-5°C (37-41°F).
But thats rather extreme, more common is a low about -5°C with then 3-5°C in the evening.
I'm looking at places prone to Chinook winds. Chinooks can raise temperatures or lower them by 50 degrees F / 28 degrees C or more. That means that it's possible that rain occurred on a day with a temperature below 0 F / -18 C!
Fort Smith, Northwest Territories had a high of 37 F / 3 C and a low of -19 F / -28 C on January 27, 1989 and had rain, but there was also snow, but it still deserves a mention (rain and -19 in the same day!)
Great Falls, MT, January 30, 2004. Weatherspark has a record of light rain, Wunderground no record of rain but a 0.00 in precip record, so a very small amount of rain probably fell.
High 39 F / 4 C, low 1 F / -17 C per Weatherspark. Wunderground has a 43 F / 6 C high but the same 1 F / -17 C low.
Great Falls, MT, November 18, 1986. High 46 F / 8 C, low 13 F / -11 C with drizzle.
We had rain on Christmas Day 2010 with a temperature of around -7C. The low that day was -12C. That could be the coldest ever, because temperatures of -12C are extremely uncommon here.
Wawa you don't need chinook winds it can actually rain as low as -20
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