They used a Helicopter in Delaware (unless my reliable source was incorrect). I was asked last summer (kiddingly) if I wanted to go up on a night count in copter. My wife works for State Parks and F&W is down the hall.

There were at least two F&W public meetings last year on QDM and 2004 proposed Deer seasons. These night counts were brought up at one of the meetings. Unless I'm getting old and goofy(possible) I'm sure it was a copter.

Anyway - whether it be a plane or copter it sounds like a reliable method to conduct a Deer count.