If you're going to generate them at runtime on the other hand, you need to seed it so in a multiplayer game everyone has the same tree (in case it has a hitbox or whatever), and you don't want to risk having crappy looking trees in important locations if that's just the one where the model didn't work so well.
Procedural generation of trees has been available forever, it didn't take ML to make it work, and it's generally not been considered worthwhile
Software suites like Houdini, which is something of an industry standard in VFX and gamedev can potentially leverage ML techniques. AFAIK the folks who make Houdini have talked in the past about using ML to improve their terrain heightmap modelling, improving the quality of the erosion etc...
The real value add with using procedural tools to automate creating parts of large worlds (eroded terrain, placement of foliage according to rules) is that it frees up artist time to focus on hand crafting individual locations and detail into the map.
There is an interesting talk from Ubisoft which talks about how they leverage tools for building their large worlds https://www.youtube.com/watch?v=NfizT369g60 (slides: https://ubm-twvideo01.s3.amazonaws.com/o1/vault/gdc2018/pres...)
If you think this is interesting, all of the Spiderman GDC talks by the various staff of Insomniac Games are S-Tier.
But perhaps GTA is a bad fit for this kind of innovation.
Having played AI dungeon, I don't think we're there yet.
https://www.reddit.com/r/GTA/comments/qs22ee/this_is_unforgi...
The idea that they hacked a bunch of ML models together to do that instead of just outsourcing it doesn't hold up to muster.