Luckily Colin not all agree with you. I have been told by people even more important than you Mr Todd, that they agree the guidance is defective and said it would be amended before publication to align definition of significant findings(Sfs) with ACOP. I will, however, believe that when I see it in print.
Now if that happens and SFs include a record of the preventitive and protective measures, the only effective way of recording these in all but very simple buidings, is by use of a plan.
If significant findings are defined as proposed RRO guidance and CFOA appear to suggest as defects only I agree, no plan would be required. A responsible person may even be able to say I have carried out my risk assessment and there are no significant findings....i.e there are no defects.
CFOAs guidance says that the responsible person should record the SFs and the action taken to deal with them!