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I'm torn on this one. You're right - you shouldn't have to put a fence up for just two dogs. BUT - what about the strays, the coyotes, and whatever else might wander through your unfenced property? You neighbor needs to be responsible to keep his dogs on his property, but YOU need to be responsible for keeping your chickens as safe as possible. I understand freeranging. We live on a farm with alot more than 38 acres around our place. My chickens free range, and I understand that if a stray dog, coyotes or anything else gets them, it's my problem because they aren't fenced in. My chickens also have a coop with attached fenced run to keep them safe if I feel the need. When we have company with dogs, the birds are in the fence. I hope you can get it all worked out with your neighbor. Good relations with neighbors can be helpful.