Tiger Woods PGA Tour 10

If you have created a custom course with St. Andrews #9 as used in numerous achievements for this game you should have no problem getting this achievement. I shot 20 under par while getting this one with ease.

Not much advice to give here -- play a round in gale force winds and stay under par. To give some context, I earned this on a round where I was -13, so it is very doable.

I'm not sure if the following advice works for all, as I play on a low def non-letterbox TV, but I generally use this method: I move the target to where the previous edge of my TV screen was for every 15 mph of crosswind I am facing. I calculate down if the wind is a partial headwind or tailwind. For headwinds and tailwinds, I generally assume moving up or down a club for every 10-12 mph of headwind or tailwind (respectively).

create a course picking one par 3 hole (one that you shoot low on normally). you can also get the bare minimum achievement easily at the same time by doing this.