It's partly a design issue with older courses when the 2 meter rule was always in effect. However, I'm not sure I see anything wrong with developing the "skill" to throw into the trees as a strategy any more than trying to throw so you land on the ground near the basket. The tree route may be more risky. But as the folks at Pro Worlds will find out this week, landing flat on the ground and avoiding roots and rough spots has its own set of luck involved.
Rater of the Tossed Arc