posted 6 months ago
Well, it depends. If there are lots of roots and not much above ground, it should take a lot to blow over the tree. Conversely, if the root structure is poor and the trunk massive, it won't take nearly as much. Additionally, since the bareroot tree was just planted there shouldn't be leaves on the tree right now which should further improve its resistance to being blown over.
If there's a decent root system relative to the size of the trunk, I wouldn't start to be concerned until the winds got above 40 mph. Also, I like to prune my apple trees to an open center, and the knee-high heading cut further improves their wind resistance.