Formatting FAT32 Volumes larger than 32 GB

For an exercise in (ahem) modding a games console, I needed to format an external USB drive to FAT32.
On doing so, I found I couldn't do so...

Microsoft Windows [Version 6.1.7601]
Copyright (c) 2009 Microsoft Corporation.  All rights reserved.


C:\Users\RMD>format g: /q /fs:fat32

The type of the file system is NTFS.
The new file system is FAT32.

WARNING, ALL DATA ON NON-REMOVABLE DISK
DRIVE G: WILL BE LOST!
Proceed with Format (Y/N)? y
QuickFormatting 238472M
The volume is too big for FAT32.

The solution I used was to find a tool that would perform the format.
Fat32Format by Ridgecrop Consultants is as good as any, i.e. it is fast and free.

C:\Users\RMD>fat32format g:

Warning ALL data on drive 'g' will be lost irretrievably, are you sure
(y/n) :y
Size : 250GB 488392002 sectors
512 Bytes Per Sector, Cluster size 32768 bytes
Volume ID is 1ee6:304a
32 Reserved Sectors, 59604 Sectors per FAT, 2 fats
7629261 Total clusters
7629260 Free Clusters
Formatting drive g:...
Clearing out 119304 sectors for Reserved sectors, fats and root cluster...
Wrote 61083648 bytes in 2.33 seconds, 25.05 Megabytes/sec
Initialising reserved sectors and FATs...
Done

C:\Users\RMD>