So I discovered something this morning and thought I'd put it out there for you guys as a challenge.
The thing to note is that these planes are not editable and have no parent relationships.
They are almost* equivalent to default planes.
* The minor difference is that we are allowed to flip normal
By the way this technique can also be used for other features. You want a default axis? No problem.
I can't imagine too many use cases, but thought you might enjoy the puzzle.
One extra clue/limitation.. It is not possible to rename them.
SolidworksModeling And Assemblies