All of our valves to dump on our new2us Cyclone are in the heated belly and do NOT freeze. Now, IF, any of the gates leak slightly, then, of course, it will freeze at the dump point IF you leave the lid on, which you are suppose to do. We never had an issue with our Raptor (Keystone). Good Luck Peggy.
In problem solving mode, you could wrap the exposed valves with heat tracing & apply some insulation. I used to have a rural property in Canada & found the most successful way to protect the water well was with heat tracing. Of course, running down the highway with road grit etc will be a problem for the insulation. Given the size & shape of the valves I can't think of any robust solutions. You'd likely have to re-insulate frequently. I don't suppose there's any way to add a valve upstream in the protected area? I know they are available with cables for remote operation.
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