I'm not talking about hunting dogs who are kept kennelled outside, their owners usually go to great measures to insure they are warm during cold weather.
It's the fools that have a dog for no apparent reason and condemn them to their backyards.......
“... whose owners keep them outside for no apparent reason”.
My Mom had a neighbor that owned a black Lab. He had that poor dog outside 24/7. There was a dog house and it was enclosed by a small fence. The dog froze to death one night. The owner? Well, he just put the poor thing in a garbage bag and shoved it onto the curb for garbage delivery. Despicable!