Our yard is half fenced because the neighbors have big ugly privacy fences. We don't fence though. The current dog and last dog were yard trained and for any dogs we don't trust we use a tie out when we can't be out with them. There aren't many times that the dogs are out without supervision.
Another problem altogether is when you say tie out most places immediately turn you down. They automatically think the dog is left out alone for long periods of time. We just use the tie out for untrustable dogs when they go out to the bathroom alone or when we are out in the yard with the untrustable dog. They are never tied out alone for any period of time.
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