Dear Steve.
There are exceptions. The pink-flowered deciduous species from China can take low temperatures/ They certainly do fine in San Francisco itself. The species that I have seen grow in the city outside without incident is P. honghenensis. But even there I would recommend taking them inside if the temperatures is going to hit 40 degrees.
Certainly none of the typical hybrids, bred from Philippine species, should be allowed to go below 50 degrees. And really they shouldn't go below 55 degrees unless they are grown "hard" in higher light and less water. Cold damage is done by moisture in spaces between the cells - plants grown "hard" have less internal moisture vapor.
Phalaenopsis hybrids can take some cold and not die, but the permanent physical damage is not very attractive and should be avoided.
Hope that helps Eric
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