plane order in assemblies

I am wondering what I could be doing to cause planes to be created near the top of the feature manager in some instances and near the bottom of the feature manager in others?  In my example, I created planes 1 and 2 and they appeared near the bottom of the tree and when I created plane 3, it appeared near the top.  It won't allow me to move any of the planes around, and i'm assuming that this has to do with the file being an assembly.

SolidworksAssemblies