Here is what I'm trying to correct shown in photos from last fall. These are not just planted whips but 3-5 years in the ground. Sometimes the whole tree leans but the central leader is pretty straight. Sometimes the bottom half is vertical and then the top bends over. I do thin apples to help with these young trees but not always as much or as early as I should. I think I took most of the apples of the tree in the first photo after taking the picture. However, it isn't always driven by fruit load. For very young trees that start to show a problem, they get a 5ft pvc stake and stretchy flagging tape but that doesn't keep them straight as they get bigger/older.
I'd like to correct the form with a tall enough stake and support it for a few years while so it takes the right shape as it matures. Otherwise, I'll likely end up pruning them back and forcing a new central leader to take over and giving it more time to grow into its size. But I hate to give up apple production when these are just starting to produce.
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