Might not be. It depends on the soil characteristics and every location is different. My neighbor has a BEAUTIFUL root cellar (10X12) that comes out from his foundation that has 8ft concrete walls, concrete ceiling, a dirt floor, and only a foot or two of dirt on top and his doesn't freeze. I'm a bit "green" every time I see it. Seeing him grab FRESH carrots out of the sand beds in his root cellar in February makes me want to cry sometimes.
This is definitely something worth considering... Im thinking if the top isnt below grade, but is insulated with a few feet of soil, that might be enough to keep it from freezing. Maybe a domed top roof, with treated plywood sheathing and covered with a heavy plastic/rubber, like that used for manmade ponds, like koi ponds, would work well... Im thinking maybe gravel floor, cinderblock walls and a wooden roof like that I mentioned above. I could do most of the labor myself, and a neighbor has a big backhoe, hed probably dig a hole fairly cheap...
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