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There are other factors that might decide where to place your fencing. If your tracks are on an embankment then the fencing will usually be at the bottom of this and if the tracks are in a cutting the fencing will usually be at the top. On level ground it will generally look better if you have a grassed verge and/or undergrowth between the trackbed and any fencing.
On model railways space is often a determining factor so a certain amount of compromise will be required.
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