My orchard has no deer fencing, but I keep my trees at a height where much of the fruit can be picked without a ladder and a short step ladder will elevate me to the rest- trees are kept under 14' tall.
But how high deer go to eat foliage and fruit varies from site to site, and my deer tend to be a lazy crew. Maybe that is because hunters in my neighborhood thin out the bucks before they get very old and large.
At any rate, it seems the coyotes, which in the east coast look like full blown wolves compared to the CA coyotes I was raised around, are really beginning to thin out the population. At some areas near me deer are back to the populations they were decades ago when there were lots of poachers.