I agree with you on this JE. That so-called planar DS is measuring the plane of the shaft (am I right?). I think the planes that one should care about are the planes of the shoulders, hands/L wrist and the clubhead, which to my mind are what matters. A shaft plane (such as what you drew above) tells us nothing, except that an over plane/flatter shaft plane to me just means there's more accum #3 available from that point onwards, an under plane/steeper shaft plane to me just means there's less accum #3 available from that point onwards.
As I've said before, I think the above planes of the shoulder, L wrist and clubhead should match at SETUP. Otherwise you'll be forever trying to match them DURING the swing.
So, why not just fix the shoulder plane, L wrist plane and clubhead plane at setup in 3D? I think the determination of these planes should start by determining the shoulder plane first.
The shoulder plane=try doing and observing and then memorizing how you will turn your shoulders during the swing--flat, level, steep, or in between...doesn't matter (though I prefer more steep than level)...when you've got this nailed down, memorize it.
L wrist plane=while doing your desired shoulder turn plane, you determine where you find your L hand to be located at impact. You may want to detach your arms, keep them connected, or in between, doesn't matter (though I prefer connected arms). Once you've observed this, do your normal swing and stop at impact position, there's your L wrist/hand plane location...
The clubhead plane=easy...now that you know the L wrist/hand location at impact, at impact you just fully uncock your L wrist and then adjust the club's grip in your L hand so that the clubhead is just exactly hovering just slightly and sweetspot on the ball.
I find my above method above very easy, foolproof, even if I adjust something in my swing.