"The plan, in addition to other requirements, needs to address the "Destruction or such other disposition of the discontinued chips and tokens..."

AHA, the crux of the regs!!!!
The approval of the plan will depend on which agent is approving the plan and their interpretation of said reg.

If I remember correctly, the regs say disposition in a manner approved by the chairman. we all know the chairman has better things to do than approve each and every plan.