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Avoid bird damage with certain tactics

Question: What can be done to keep birds from eating all the fruit in an orchard? My brother has an orchard in southern Utah. There are about 100 trees, mostly dwarf and semi dwarf. Last year, birds got 90 percent of the fruit. He has tried scarecrows, but that didn’t work. He has also tried aluminum foil pie tins, but that only worked temporarily. Is there any solution for him other than buying netting to cover the trees?