Hi Karen,
        Until your trees are well-established (in three years)  I would keep them
fenced.  My thirteen year old Berner still undermines our planting efforts
in the dog yard with occasional help from our six year old Berner.
After three years remove the fence from one tree a month.  Our oldest
Berner generally accommodated this practice unless it was a place that she
really wanted a deep dirt burrow.
Best of luck,
Barb Lindman and the Berner farm girls of Iowa - Kari 13 years 4 months and
Anja six years 8 months.

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