I think you want to be in the ballpark of the club's lie angle (as per some earlier posts by Brian et. al). As far as a range goes, I've seen some very good players with Vertical Plane's consistently 10 degrees off that lie angle (with a driver).
Good question; I'm interested to see others' input.
Also, I'm not sure we know the range that Hogan's Impact Plane would have had. He had a flatter look to his "swing plane," but that doesn't necessarily result in a flatter Impact Plane (that which is measured by Trackman & Flightscope)...at least in my opinion.