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The answer to that could only truly be answered by Stephen Hillenburg. However, you can hypothesize that Sandy's treedome is very technologically advanced, and has a superior climate control system, that can make is snow inside the dome even when outside is warm. Either that, or don't think about it too much: it's a cartoon and it had to be snowing for the joke to work.

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Q: How is it that when its winter in sandy's Dome When its Not Snowing in Bikini Bottom?
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