Wanted to throw in my solution for this as well. I can confirm that getting a hole in one on a par 4 does count towards this achievement.
The place where I most consistently got this was on Space Station, hole 7. When you start, there will be two black holes between you and the pin. The pin is at the far back wall and is in a recessed area of the green. If you turn your view to the right, you'll notice a triangle block sitting lower than the wall. Aim for the middle of this block and set putt strength to full power. Using this method I was able to get a hole in one (3 under par) about 90% of the time.
Picture for reference: