My first thought on this was it should be okay on the outside of a fw bunker, following the Ross dictum of more penalty the further you hit it off line. That said, I would be most double penalties were not a result of the architect striving for that, but rather that trees grow and no one accounts for that in placing the near fw bunkers. Or, some green committee planted the tree as part of their program, and it probably wasn't a hazard when new. (Cue the old Sam Snead joke...."Son, when I was your age, I could clear that tree. Of course, it was just a sapling then."