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It can't if it is "well" above freezing, but certainly if it is only a few degrees. The surface on a calm, cold night will radiate heat away from it rapidly. If there is little wind to mix the air, the coldest air near the surface will sink to the ground so that the temperature right at the surface where frost forms is at or just below the freezing point, while just above that where temperature is officially measured (2 meters) it can be several degrees warmer.

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