Saplings can not grow a tree when there is snow on blocks it would normally be able to replace [I.E. minecraft:oak_leaves, minecraft:spruce_leaves, etc.]. This feels like something that should normally be allowed and it makes farming trees in cold biomes quite annoying.
As this is purely something related to the code, I left the environment details blank.
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Can confirm. It's noteworthy that MC-13431 has been fixed seemingly indicating that external features of trees should not impede sapling growth.
Can confirm behavior, 1.20.3 pre2