I think it is a statement largely mis-used by people who don't understand strategy. They tend to look at some courses as not testing the driver, merely the approach shots, becasse these courses lack OBVIOUS challenges to the drive: water, ob, heavy penal rough, penal bunkering, etc. But all the while, they completely overlook how a drive in the proper location would help the approach shot, sometimes immeasurably.
It's a sort of backhanded compliment/insult, depending on how you look at it.
It reminds me of the expression "This course requires every club in the bag". I personally would rather a course ask me to hit high approach shots, low runners, safe shots, bold shots, etc., rather than simply asking me to hit drop and shot shots from a variety of distances.