It doesn't mean, MM, that it is not associated with an upper-low. Look at the water vapor imagery; you'll see what I mean. Also, "an area of disturbed weather" does not imply a low-level circulation or even a surface feature...just that something is there. There *might* be a low-level circulation trying to form, but it is directly connected to that upper-low, the convection is being forced by diverging winds aloft, and the only model that picks up on such development -- the Air Force MM5 -- has its development as a very weak, cold core system.

Getting Bret out of that would have to come quick, as the waters get cool in a hurry, and anythnig that happens there wouldn't be quick. Shear isn't favorable, either, though not necessarily horrible. The upper low it is associated with -- just like the last one -- is the main player. It's what is forcing this the convection, really.