Anything short of a 10' fence repel deer from fruit trees?

[Ed of all trades]

My Mississippi relatives use the "single strand electric fence with peanut butter" method to protect about an acre of watermelon patch. Just smear some peanut butter on the wire (fence off) then turn the fence on. They will sniff and lick the peanut butter and get a good jolt. Apparently they are smart enough to not come back. I think of it as a "Jiffy fence".

I know this works but we put ours at 18", I have had a heard of deer in the field around my garden and not a deer track in it. We ran the same fence beside the road and the deer would not even go there when the hounds were after them. Hunting with hounds is legal in central Va.