Rich,
That's a legitimate question. Any time a designer starts looking at ways to challenge the best players, he punishes the others 4X, at least IMHO.
I would say it's strategic, but in grey shades, with an execution requirement that is pretty difficult. Add in a harsh penalty for a near miss and some will question whether that combo is more penal than strategic, and in fact, at some point, its probably possible to create a strategic hole that becomes penal in fact, if not in theory.
I know Tom hates it when I speculate......
So to be fair, I am speculating based on a par 3 at Rawls my son hates, mostly because its a crowned green with false front that takes a shot that hits the green, but about a yard short of where it needs to be, and rolls it back about 30 yards back towards the tee. As you can imagine, he was not happy, feeling he is a scratch or plus player, and he hit it within a few yards of the flag, and.........but I saw Tom's strategy even as a less than neutral bystander!
In green design, the options are to conceptually to make a green that is:
All receptive from anywhere, perhaps even helping with concave slopes
Mostly receptive, but has one or two pin spots requiring specific shots or approach areas.
Make an entire green that accepts only shots from a certain area or of certain trajectory.
Make a green that is just hard to hit from anywhere.
Its also possible to vary the penalty for an indifferent shot. You can design false fronts and sides that kick shots far from the green or fw chipping areas near green level that are only a smidge harder than a putt.
Personally, it seems like the harder the entire green is to hit, generally the lesser the penalty ought to be. If the green is somwhat receptive in some areas, then the Sunday pin areas can be tougher by virtue of size, slope and hazard. As the chances of missing the entire green rise because of wind, contours, size, etc., it seems logical to mostly create an easy "leave" to compensate.
Of course, there are always exceptions and a few spice up a course. It just seems that really hard to hold greens aren't well recieved by the golfing public, at least until the course is as famous as Pinehurst No. 2.
I think that's what you do to create a great championship course, but most gca's get beaten down over time, and start accomodating more average players who think less on their one trip a year to the high dollar resort/upscale public.