The saku that were located as military footholds by the Abe clan of Oshu and the Dewa Kiyohara clan during Zen Kunen no Eki (the Early Nine Years' War) and Gosannen no Eki (the Later Three Years' War) were different in nature from 'josaku,' so they are generally not included in the 'josaku' discussed here.
前九年の役、後三年の役で安倍氏(奥州)や出羽清原氏が軍事拠点として設置した柵は成り立ちや性格が異なるので、一般的にはここでいう城柵には含めない。