Unconfined uniaxial creep tests were conducted at —8.5°C on sand-ice samples with an average wet density of 124 pcf (1,986 kg/m³). The samples were 94% water saturated, on the average, prior to freezing. Thus the data represent the behavior of slightly undersaturated frozen sands. Stress-strain data for different durations of loading were obtained by replotting the creep data. Values of the stress characterizing the change in stress-strain relations are confirmed by creep rate-stress data. It is shown that use of a single continuous stress function to represent stress-strain data in models must be limited to either stresses greater than, or less than, the limiting long-term strength. A single continuous stress function cannot represent realistically the entire stress range.