1) You live in a totally urban location with zero deer population.
2) Your region is a desert or area with zero deer present (not common!)
2) Deer protection is installed in your orchard.
What about the other options like sprays and dogs? Deer sprays are an ineffective waste of money, dogs only help sometimes and pie pans and scare tactics are a joke.
So what's the best form of deer protection? An 8-Foot tall deer fence. However, you may not want this or cannot afford it, or you only have or plan on having a small orchard of 4-8 trees. What to do then? The answer is simple: mini fences around each tree. This is affordable, easy and really works. Deer can still nip the edges of the tree, but cannot rub the trunks or eat the tree completely. This works! We've had only minimal, negligible deer damage since using these home-made cages since 2014.
Here's What you'll need:
*Wire Cutters or Tin Snips
*Rebar posts (5 FT tall ones used for electric fencing work great) or 5 FT tall metal T-Posts.
All three of these items can be purchased at any quality hardware or farm store.
Here's how it's done: Un-package your 4 FT tall chicken wire and unroll a 12 foot section, weighing it down. Cut each piece length-wise with wire cutters or tin snips to be 12 FT long. We like to weigh down the chicken wire with a block or something heavy so it does not try to roll back on us. You'll now have a 12 FT x 4 FT piece of chicken wire.
Take the posts to your tree. Measure 2 FT from the tree base in any direction. Put the first post in this spot. Now measure 2 FT from the tree base in another direction, put the 2nd post. Now measure 2 FT from the tree base in another direction, put the 3rd post. Try to make it so that the posts are pretty much equally spaced, like a triangle, around the base of the tree. You can use as little as 1 post or as many as you want, but 3-4 works well.
Now, connect the chicken wire together using it's own cut ends. Simply put the cut ends through the holes and bend backwards, to lock it together. You'll be left with a large 4 ft wide hoop of wire. Next, slide the wire over the posts so that the posts weave in and out of the chicken wire, for strength. Slide it all the way down to the ground. You're done! Now you can rest easy knowing deer won't tear your trees up.
This is also recommended used on berry bushes in high deer-pressure areas.
For even better protection, woven wire fencing or cattle panels can be used instead of chicken wire, with posts adjusted to fit those materials.
See the picture below of a protected fruit tree at our nursery. Note three rebar electric fence posts used, thick mulch and 4-Ft chicken wire. That's a happy, safe tree! Total costs is around $10-14.00 per tree depending on local prices, etc.