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If a sub-tropical storm developed in January (highly unlikely) it wouldn't be part of any season as the hurricane season runs from June 1st to Nov. 30. NHC would handle it though, and issue adv's.
I know we're drifting further and further off topic, but Ana in 2003 formed in April and was considered a part of the 2003 season. I was just curious if there was a cut off for the season besides the Dec 31/Jan 1 date...
-Mark
Ana in 2003 is the earliest that a storm has been given a name. It was named Tropical Storm Ana on April 21.
There was a subtropical storm that formed in January of 1978 that was not given a name, but is on the list of 1978 storms. So I'd imagine any storms forming after 12/31 go to the following year.
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