Tom MacWood,
For me, I would agree that the greatest tests are a proper combination of strategic and penal design.
For others, I think it is a matter of degrees.
For some, every bunker is penal, for others bunkers offer no impediment to the shot at hand. (Witness Tiger's incredible
6-iron from 218 yards over water to a tucked pin)
I think there has been a clear movement away from penal designs. I think Pete Dye was controversial because he began a return to penal design.
If you look at the great number of golf courses created in the last twenty years, for resorts, or communities, who would design a penal course ?
On muni's, who would design a penal course ?
At for profit clubs, who would design a penal course ?
For me, for the most part, penal designs exist more in the classic courses than the modern courses.
I just can't imagine someone designing GCGC or PV for a resort, community, muni, or for profit use. I can't imagine a course that I love, that combines penal and strategic better then most, NGLA, being put into the above use categories.
I think penal design is rare today.
Perhaps it will return, I doubt it, but, I hope so.