Power  Golf
As mentioned on the Stage Three - Your Biomechanics web page, there are 12
biomechanical features related to the biomechanics of a sound swing; four (4) of the
features relate to the fundamentals of Accuracy, four (4) of the features relate to the
fundamentals of Power, and four (4) of the features relate to the fundamentals of
Good Feel.  Also keep in mind that each of the 12 biomechanical features have 3
options.  On this page we will overview the 4 Biomechanical features related  to
Accuracy.  Study these features and familiarize yourself with the 3 options related to
each feature.  Simply familiarize yourself with the basic patterns.  If you are
interested in studying them in more detail you will be able to purchase a series of
books related to the Power of 3 Golf Biomechanics.  There will also be DVD's and
downloads available in the future.
This page was last updated 05-22-09
3
B  I  O  M  E  C  H  A  N  I  C  S
Related To The Fundamentals of Accuracy
Copyright 2009 Ed Tischler / New Horizons Golf Approach. All rights reserved.

If you have any questions regarding New Horizons Golf Approach please contact
Ed Tischler at (408)203-7599, or email your questions to Ed Tischler

new
horizonsgolfer@yahoo.com.
New Horizons Golf Approach
I n n o v a t i v e  C o a c h i n g  F o r  G o l f e r s

Below we will show pictures and provide descriptions of the 4 biomechanical features related    
to Accuracy.  In doing so we will cover the three options related to each feature.  Keep in    
mind we are overviewing these features.  In the future you will have the opportunity to learn   
more about how to test yourself, and how to apply the knowledge found on these pages.
As a reminder, the Power of 3 Golf Biomechanics related to Accuracy:

Swing Paththere are 3 possible dominant forearm actions.
Swing Trackthere are 3 possible elbow actions for elevating and levering during the backswing.
Lever Wrist Actionthere are 3 possible ways for the wrists to load leverage while hinging.
Lever Delivery Action there are 3 possible ways of releasing the swings stored leverage.


As mentioned above there are 3 options for each feature.  The options for the
biomechanics related to the fundamentals of accuracy are listed below.


Power of 3 Golf Biomechanics related to Accuracy:

Swing PathOn-Top, Side-On, & Under
Swing TrackLow, Mid, & High
Wrist Lever ActionHorizontal, Vertical, & Diagonal
Lever Delivery ActionCovering, Cornering, & Extending
    As already mentioned there are three Arm Swing Paths discussed in Power of 3 Golf biomechanics.  These three
features are On-Top, Side-On, and Under swing paths.  When we talk about swing paths we are talking about the
manner in which your dominant forearm is aligned as the stroke moves through the takeaway and delivery.  For right-
handed golfers the dominant forearm is the right forearm, for left-handed golfers the dominant forearm is the left
forearm.  If you are ambidextrous, a right handed person playing left handed golf, or more likely a left-handed person
playing right handed golf, your dominant forearm is the forearm that matches the side you are playing golf from.  For
example, if you are left-handed playing from the right-handers side your dominant forearm is your right forearm.  For
example, Ben Hogan is said to have been born left-handed, however he played from the right-handers side.  Doing
so he believed the right arm delivered the swing and he swung the club 100 times a day holding the club in his right
hand only.  In his book Five Lessons: The Modern Fundamentals of Golf Hogan described the proper arm swing path
for delivery as a type of side-arm throw.  He clearly understood the importance of the dominant forearm swing path.
 However, Hogan’s description was only one of three viable options.  On-top golfers deliver the swing while the
dominant forearm faces more downward.  This would be as if you were throwing something down at the ground near
the ball address location. With this in mind, on-top golfers often feel a palm down delivery action.  This feeling is truly
a sign of being on-top.  Side-on golfers deliver the swing while the dominant forearm faces more to the side.  This is
as you were trying to throw a ball to the side of you on about a waist-high trajectory.  Side-on golfers often feel a
more cornering type of delivery action.  Under golfers deliver the swing while the forearm is facing more upward.  This
would be as if you were throwing a rock in such a manner to skip it across water.  Under golfers often feel a more
down the line delivery action.
 Another way to think about these actions is the manner in which you would move on-top of something, move
something to the side, or pick something up.  For example, if you had to get on-top of a counter you could position
your hands palm down on the counter and push yourself up on the counter.  In doing so your forearms would face
downward.  You can also think of it as if you had to push something downward with your dominant hand.  You can
also think of it as replacing a lid on a garbage can while holding the handle with only your dominant hand.  In either
case you would also position your palm downward.  You could also position your forearm downward to do so.  If you
needed to move a box to the side on a shelf you would position your hands on each side facing inward.  This could
position your forearms in a more side-on facing manner.  From here you can easily move the box to the side.  Even if
you were only going to use your dominant hand to push the box to the side you would use the same technique.  It
would simply be one-handed.  Under golfers position the dominant forearm as if they were going to pick something
up.  To pick up a box for example I can slide my hands under the box positioning my forearms in a more upward
looking alignment.  If you were going to pick up a dumbbell and perform a standard dumbbell curl you would also hold
the dumbbell in an under manner with your palm and forearm facing more upward as your forearm is positioned
parallel to the ground.  This brings me to an interesting conditioning fact.  When it comes to working out I encourage
on-top golfers to perform more reverse curls than standard or hammer curls.  Reverse curls are performed with the
palm facing downward as the forearm reaches parallel to the ground.  Hammer curls are performed with the palms
facing inward, and standard curls are performed with the palm facing upward as the forearm reaches parallel to the
ground.  Although performing a variety of each is recommended, performing extra repetitions of the style that
matches your arm swing path is highly recommended.  This means side-on golfers perform extra hammer curls and
under golfers perform extra standard curls.
 It is also important to discuss how your elbow action responds to each of the basic swing path options.  This is
because your elbow is the link between your forearm and your upper arm.  This is important because the manner in
which your elbow folds to elevate the club during the lever loading action is tied into how your forearm action works.  
In this manner your swing-path and swing-track actions are connected.  This means your elbow action must match
both your swing-path and swing-track actions.  
 An easy way to understand how your elbow action matches your swing path is to perform a basic exercise. To
perform the exercise stand-up and hold your right arm straight out in front of you (see pictures).  For left-handed
golfers hold your left arm out in front of you.  With your arm in front of you tuck your elbow in front of your body.  
Tuck it into a position just to the side of your belly button.  Notice that it is easiest to do this when the forearm is
facing more toward the sky, and this puts it in an under attitude.  Try to keep your forearm in either a side-on attitude
or an on-top attitude and move your elbow in front of your body.  It will be impossible, or nearly impossible depending
on your biomechanics.  However, everyone finds it much easier to tuck the elbow in front with an under forearm
attitude.  Now, hold your arm out in front of you once again, and then pull your elbow to the side of your body.  Pull it
to the side so that the elbow is even with the seam line of your shirt.   Once again notice where the inside portion of
your forearm is facing.  It will be facing inward in a side-on manner.  This is the most natural way to position the arm
on the side of the body.  Now, hold your arm out in front of you once again, then move your elbow back and around
toward your spine.  The easiest way to do this is to put your hand in a palm down position.  If you make your elbow go
back while maintaining either an under or side-on attitude the action will become restricted.  Once you adjust your
forearm into an on-top position you will be able to move your elbow even further back and around.  
 By understanding how these actions work naturally, we can understand just how your elbows act in the golf swing.  
What this tells us is that under golfers will tuck the dominant elbow in at address, during the takeaway, and into
delivery.  By feeling the elbow tucked in during delivery, under golfers are sure to deliver the swing in an under
manner.  Side-on golfers will position the elbow at address so that it is easy to marry the right arm to the right side
during the takeaway and transition down toward delivery.  By marrying the right arm to the right side, side-on golfers
are sure to deliver the swing in a more side-on manner.  On-top golfers will use and elbow-back takeaway and a
more elbow-back delivery.  By delivering the swing with a more elbow-back attitude, on-top golfers are sure to be
more on-top throughout the delivery action.  Therefore, be attentive to you elbow action in the golf swing.  Be sure to
match the elbow action with the type of arm swing path that fits your needs.  It will help you master the delivery action
you need to own your swing.  

1) Start with your right arm extended out in front of your         
     body as shown in the far left picture.

2) Then tuck your elbow in front of your body, somewhere      
     to the side of your belly button.

It is much easier to tuck your elbow in front of your body         
while positioning the forearm to face upward in and under      
attitude.

It is very constricted to do so with a forearm that is facing       
inward, or in a side-on attitude.  It is almost impossible to        
do so with the forearm facing downward or in an on-top          

1) Start with your right arm extended out in front of your       
    body as shown in the far left picture.

2) Then pull your arm to the side of your body until your       
    elbow is even with the seam line of your shirt.

The most natural way to do so is to position your forearm     
facing inward in a side-on manner.  

When positioning the forearm either up or downward you     
will feel more tension in your arms and shoulders.

This makes the old adage of marrying the right arm to the    
right side mainly a side-on action.

1) Start with your right arm extended out in front of your         
    body as shown in the far left picture.  Then pull your arm   
    behind you while trying to get the elbow back around         
    toward your spine.

2) The most natural way to do so is to position your               
     forearm facing downward in an on-top manner.  

When positioning the forearm so that it faces downward         
you will be able to move the elbow further around than you    
would with the forearm facing either inward or upward.  If       
you first do so in a side-on manner, then turn your forearm    
so your palm is facing down you will be able move your          
elbow further back and around.
Swing Path Biomechanics:
On-Top, Side-On, & Under options

The four pictures above demonstrate the three basic swing path patterns used during the initial        
move in the golf stroke.  The patterns are being demonstrated without a golf club so that it can be           
more clearly understood what the forearm is doing.  Remember, swing path biomechanics is about the    
dominant forearm action.  1)  Picture one shows the basic address position.  2)  Picture 2 shows the        
basic Under Swing Path takeaway move.  Notice how Ed's right forearm is facing up toward the sky,         
which is an Under alignment.  This is the basic Under Move.  3)  Picture 3 shows the basic Side-On         
Swing Path takeaway move.  Notice how Ed's right forearm is facing more inward, which is a side-on        
alignment.  This is the basic Side-On Move.  4)  Picture 4 shows the basic On-Top Swing Path                 
takeaway move.  Notice how Ed's forearm is facing more downward toward the ground, which is an          
On-Top alignment.  This is the basic On-Top Move.

The four pictures above demonstrate the three basic delivery patterns used as the stroke enters the    
impact interval.  The patterns are once again being demonstrated without a golf club so that it can be     
more clearly understood what the forearm is doing.  Remember, swing path biomechanics are about       
the dominant forearm action.  1)  Picture one shows the basic address position.  2)  Picture 2 shows        
the basic Under Swing Path delivery move.  Notice how Ed's right forearm is facing up toward the sky,     
which is an Under alignment.  This is the basic Under Move.  3)  Picture 3 shows the basic Side-On         
Swing Path delivery move.  Notice how Ed's right forearm is facing more inward, which is a side-on           
alignment.  This is the basic Side-On Move.  4)  Picture 4 shows the basic On-Top Swing Path                 
delivery move.  Notice how Ed's forearm is facing more downward toward the ground, which is an             
On-Top alignment.  This is the basic On-Top Move.

The four pictures above demonstrate the three basic swing path patterns from the down the line           
view, once again notice the alignments.  Remember, swing path biomechanics is about the dominant       
forearm action.  1)  Picture one shows the basic address position.  2)  Picture 2 shows the basic              
Under Swing Path takeaway move.  Notice how Ed's right forearm is facing up toward the sky, which is     
an Under alignment.  This is the basic Under Move.  3)  Picture 3 shows the basic Side-On Swing Path    
takeaway move.  Notice how Ed's right forearm is facing more inward, which is a side-on alignment.         
This is the basic Side-On Move.  4)  Picture 4 shows the basic On-Top Swing Path takeaway move.         
Notice how Ed's forearm is facing more downward toward the ground, which is an On-Top alignment.       
This is the basic On-Top Move.
    As we study Swing Path biomechanics you can think of the basic actions in terms of other athletic
actions.  For example,  The basic Under Swing Path is used in tennis to play a drop shot or a cut shot.  
The Side-On Swing Path was used in the old days of tennis to play the standard ground stroke.  The basic
stroke was taught to me by my father when I was growing up.  He reminded me to keep my forearm facing
forward instead of upward or downward.  This is the basic side-on alignment.  If you wanted some extra
topspin you would roll the forearm so it faced downward through the impact interval.  I am sure you can
find many other examples in sports and life that relate to these basic paths.  Interestingly enough in
tennis, many different types of grips and racket alignments have been developed to help players with
very biomechanics be able to make the proper adjustments in their own individual games.  
Swing Track Biomechanics:
Low-Track, Mid-Track, & High-Track options
 As already mentioned their are three Swing Track options in the Power of 3 Golf biomehanics
system.  The three swing track options are Low-Track, Mid-Track, and High-Track.  As you study the
Swing Track feature you may notice that other teachers, methods, and systems have introduced
concepts related to Swing Track biomechanics.  By understanding Swing Track biomechanics you will
be able to more thoroughly understand how those methods work and whether those methods fit your
individual needs.  Below are three pictures depicting the basic top-set positions related to
Low-Track, Mid-Track, and High-Track biomechanics.   
 The far left picture above shows a Low-Track top of the backstroke position.  Notice how we can see some of
Regie's shoulder above his lead arm (his left arm) at the top of the backstroke.  This is a classic Low-Track top of the
backstroke position.  The middle picture above shows a Mid-Track top of the backstroke position.  Notice how Ed's
lead arm (his left arm) is aligned directly through his right shoulder.  This is a classic Mid-Track top of the backstroke
position.  It has been popularized in recent years as being the ideal alignment at the top of backstroke.  Hank Haney
is one of the more famous instructors advocating this type of top set alignment.   There are many great players using
this concept in today's game.  The far right picture shows a High-Track top of the backstroke position.  Notice how
the lead arm (right arm) is aligned more vertical than the shoulder line.  During the 1970's and early 1980's this top
of the backstroke position was popularized by the famous adage, "High hands in the backswing-High hands in the
finish."  When we think of High-Track players, Davis Love III, Fred Couples, and John Daly come to mind.   Many
students often ask what are the advantages to one or the other patterns.  When it comes to biomechanics the only
advantages is discovery which one fits your machinery.  Your body is built to use one of the three options efficiently.  
Attempting to use either of the other two will always be problematic.   

In recent and past years other professionals have noticed these patterns and built their systems around them.  For
example, Jim Hardy has his One-Plane and Two-Plane systems.  As Ed studied his books it became clear that what
Jim Hardy calls a One-Plane swing uses the Mid-Track feature as the ideal One-Plane model.  However he also
expresses that if the lead arm is aligned below the shoulder line than it also qualifies as a One-Plane model.  The
definition of a Two-Plane swing is one in which the lead arm swings upward at a different angle than the shoulder
line.  Therefore, it seems that his One-Plane swing model is one in which the lead arm and shoulder line are aligned
on One-Plane at the top of the backstroke.   In reality a Low-Track top of the backstroke position aligns the lead arm
at a different angle than the shoulder line.  Thus it would simply be a different type of Two-Plane swing.  When
biomechanics are applied, the argument of One-Plane or Two-Plane simply goes away.  Instead of defining the
top-set position in  terms of plane angles we define them in terms of assembling the leverage components of the
arms, wrists, hands, and club.  The reason some golfers lever the backstroke action into a Low-Track top of the
backstroke position, while others do so into a Mid-Track top of the backstroke position, while others do so into a
High-Track top of the backstroke position is that this is the best way their individual bodies can establish the system
of leverage accomplished by the arms as the swing strives to maximize structural leverage.  Keep in mind that other
instructors and systems argue their version of One-Plane and Two-Plane theory as well.  As we continue to discuss
all the biomechanical features their theories will be clarified as well.    

An example of another system that has identified these basic top of the backswing positions in their system is the
LAW's system by Adams, Tomasi, and Suttie.   As Ed studied their system and compared it to the biomechanics he
had studied it became clear to him that the Leverage Player described in the book used Mid-Track biomechanics, the
Arc Player described in the book used High-Track biomechanics, and the Width Player described in the book used
Low-Track biomechanics.   In Ed's opinion, the way the LAW's system assembles the LEVERAGE PLAYER
recommendations renders the LEVERAGE PLAYER a swinger as compared to either a hitter or thrower.  He also
views the recommendations for the ARC PLAYER as rendering the ARC PLAYER as a thrower as compared to a
swinger or hitter.  Lastly, he views the recommendations for a WIDTH PLAYER as rendering the WIDTH PLAYER as a
hitter as compared to a swinger or thrower.  As far as biomechanics is concerned, you can develop your stroke into
either of the three golf actions with each of the Swing-Track Options.  You can be a High-Track Swinger, Hitter, or
Thrower.  You can be a Mid-Track Swinger, Hitter, or Thrower.  And, You can be a Low-Track Swinger, Hitter, or
Thrower.  The key is to discover your biomechanical options first, then assemble them in whatever action suits your
needs and disposition.  In general Ed Tischler recommends you do you best to develop a Swinging style of golf
stroke.  This is because his studied have shown that it tends to be the action that is most efficient while producing
effortless power and maximum control.  It also ensures greater longevity and less physical problems.  However, there
will be some of you that have individual concerns that will make either the throwing or hitting action more suited to
your needs.   In the end, the type of golf action you use, swinging, hitting, or throwing, will simply be a matter of
choice.  However, your biomechanics are your biomechanics, because your biomechanics are based on how the
machine of your body is constructed.  
Lever Delivery Biomechanics:
Covering, Cornering, & Extending options
As we study the biomechanics of how the wrist action creates leverage we come to understand that the wrists have
three basic ways of hinging while levering the golf club.  Picture 1) above shows the basic starting position for feeling
how these hinge actions work.  Take hold of the club and position it parallel to the ground at waist high. Picture 2)
shows the horizontal hinge action.  From the starting position you simply hinge your wrists so that the Picture 4) shows
the basic vertical hinge action.  From the starting position you simply hinge your wrists vertically upward so the club
shaft moves vertically up to your nose.  Picture 3) shows the basic diagonal hinge action.  From the starting position
you simply hinge your wrists so that the shaft of the club moves upward and to the side at an angle that is close to
your right shoulder (left shoulder for left handed golfers).  

The key is to discover which wrist hinge action produces the most structural leverage in your own unique situation.  
Many things contribute to the structural leverage you produce as you hinge your wrists.  The exact alignment of each
hand in relations to the shaft and each other, where you us a long thumb or short thumb condition in your left hand
hold, whether you use a ten-finger, reverse overlap, overlap, or interlocking grip, and the actual structure of your
wrists.   Golfers that tend to have shorter and more stiff wrists tend to you vertical hinging.  For example, Tim Clark
(PGA Tour Player) cannot roll his wrist and forearm to face his palm up in the air.  When he gets change at the
drive-thru, he holds his hat out with his wrist in a vertical alignment so that the teller can put the change in the hat.  
This will certainly influence the way he hinges his wrists.  Once again, the key is to discover which action fits your
specific biomechanical needs.  All three options are valid, what make one more appropriate than another is whether it
fits your make-up or is a mismatch for you biomechanics.
Wrist Lever Biomechanics:
Horizontal, Vertical, & Diagonal options
The above sequence of photos shows the basic dominant arm action for the covering delivery action.  The
covering delivery action is usually used by golfers that own an On-Top Swing Path option.  (1) From the
basic address position (2) notice how the takeaway is performed in an On-Top manner with the forearm
facing downward.  Picture (3) shows a palm down delivery action which is used to create the first half of the
covering feel.  Picture (4) finishes off the covering delivery with an extension that is achieved shortly after
impact.  Once again the palm is facing downward.  It is also facing inward and this completes the covering
feel.  In the sequence below we will see the same action from the target view.
The above sequence of photos shows the basic dominant arm action for the covering delivery action.  The
covering delivery action is usually used by golfers that own an On-Top Swing Path option.  (1) From the basic
address position (2) the takeaway is performed in an On-Top manner with the forearm facing downward.  
Picture (3) shows a palm down delivery action which is used to create the first half of the covering feel.  
Picture (4) finishes off the covering delivery with an extension that is achieved shortly after impact.  Once
again the palm is facing downward.  It is also facing inward and this completes the covering feel.
The above sequence of photos shows the basic dominant arm action for the cornering delivery action.  The
cornering delivery action is usually used by golfers that own a Side-On Swing Path option.  (1) From the
Side-On backswing alignment (notice how the forearm is facing toward the side view) (2) the stroke moves
into a Side-On delivery action (once again the forearm is facing Side-On).  Picture (3) demonstrates the
Side-On extension, one that is already beginning to corner.  Picture (4) finishes off the cornering delivery
with a follow-thru that corners around to the left (right for left handed golfers) as it moves slightly above waist
high.  Once again the forearm is facing Side-On.  In the sequence below we will see the same action from
the target view.
The above sequence of photos shows the basic dominant arm action for the cornering delivery action.  The
cornering delivery action is usually used by golfers that own a Side-On Swing Path option.  (1) From the
Side-On backswing alignment (notice how the forearm is facing toward the side view) (2) the stroke moves
into a Side-On delivery action (once again the forearm is facing Side-On).  Picture (3) demonstrates the
Side-On extension, one that is already beginning to corner.  Picture (4) finishes off the cornering delivery
with a follow-thru that corners around to the left (right for left handed golfers) as it moves slightly above waist
high.  Once again the forearm is facing Side-On.
The above sequence of photos shows the basic dominant arm action for the extending delivery action.  The
extending delivery action is usually used by golfers that own an Under Swing Path option.  (1) From the
Under backswing alignment (notice how the forearm is facing more upward) (2) the stroke moves into an
Under delivery action (once again the forearm is facing upward).  Picture (3) demonstrates the begining of
an Under extension delivery, one that is already beginning to push down the line.  Picture (4) finishes off the
extending delivery with a follow-thru that extends down the line toward the target as it moves thru shoulder
high in the follow-thru.  In the sequence below we will see the same action from the target view.
The above sequence of photos shows the basic dominant arm action for the extending delivery action.  
The extending delivery action is usually used by golfers that own an Under Swing Path option.  (1) From the
Under backswing alignment (notice how the forearm is facing more upward) (2) the stroke moves into an
Under delivery action (once again the forearm is facing upward).  
Picture (3) demonstrates the begining of an
Under extension delivery, one that is already beginning to push down the line.  Picture (4) finishes off the extending
delivery with a follow-thru that extends down the line toward the target as it moves thru shoulder high in the
follow-thru.  In the sequence below we will see the same action from the target view.
To acquire a feeling of how the horizontal hinge lever action works (1) start in the beginning position.  (2) Then hinge
your wrists so the club shaft moves horizontally, parallel to the ground, until the shaft is also parallel to the ball line.  
Your hands will remain at waist high. (3) Next, bend from your waist and assume an athletic posture.  (4) Finish off the
backswing while maintaining the horizontal lever action.  (5)  Notice how the clubface faces more toward the sky than
in traditional teachings.  The leading edge of the clubface is closer to parallel to the ground then it is to being on
plane.  This is often described as a closed clubface position at the top of the backswing.  It is actually more square to
the arc of the swing.You can also view this clubface position in the larger picture below.  
To acquire a feeling of how the vertical hinge lever action works (1) start in the beginning position.  (2) Then hinge
your wrists so the club shaft moves vertically toward your nose.  Your hands will remain at waist high. (3) Next, bend
from your waist and assume an athletic posture.  (4) Finish off the backswing while maintaining the vertical lever action.
 (5)  Notice how the clubface is aligned in such a way that the toe of the club is hanging nearly straight down.  This is
known to be an open clubface alignment at the top of the backswing.  It truly is open because it is open to both the arc
of the swing as well as the plane of the swing.  You can also view this clubface position in the larger picture below.
To acquire a feeling of how the diagonal hinge lever action works (1) start in the beginning position.  (2) Then hinge
your wrists so the club shaft moves diagonally to the right at about a 45 degree angle between the horizontal and
vertical alignments.  Your hands will remain at waist high. (3) Next, bend from your waist and assume an and vertical
alignments.  Your hands will remain at waist high. (3) Next, bend from your waist and assume an clubface is
positioned in such a way that it is aligned exactly on the same plane as the left arm.  This is known to athletic posture.
 (4) Finish off the backswing while maintaining the diagonal lever action.  (5)  Notice how the athletic posture.  (4)
Finish off the backswing while maintaining the diagonal lever action.  (5)  Notice how the clubface is positioned in
such a way that it is aligned exactly on the same plane as the left arm.  This is known to be a square clubface
alignment at the top of the backswing.  In reality it is an on-plane clubface alignment, and an on-plane clubface
alignment is open to the arc of the swing and needs some squaring to return the clubface square through the golf
ball location.  You can also view this clubface position in the larger picture below.
In picture (1) the clubface faces more toward the sky than is traditionally taught as being recommended.  This is
traditionally considered a closed clubface, however it is actually a square to the arc of the swing clubface alignment.  
In picture (2) the clubface is aligned so the toe of the club is hanging vertically downward.  This is traditionally
considered an open clubface and it is truely open to both the arc of the swing and the plane of the swing.  In picture
(3) we see the clubface aligned exactly on the plane of the left arm.  This is traditionally considered a square
clubace alignment.  It is actually an on-plane alignment and an on-plane alignment is open to the arc of the swing
and requires some squaring action to delivery the clubface square through the ball.  All three lever hinge actions
are valid and all three top-set positions are valid.  The questions is which one fits your biomechanical needs.