I thought the ground plane would be created by any flat surface below the TIP of the antenna, regardless of where the base is located.
Flat or not; below the antenna or not; any metal on the truck that's grounded in common with the transmitter's power supply will act as a ground to the radio waves. But the waves bounce off each of those objects, like sunlight bouncing off a crowd of umbrellas; each one creates a "shadow", so the waves won't hit things that are hidden from the antenna (like the engine under the hood, and the axles under the body). If some of those surfaces are higher than others, then some of that energy will be lost as it bounces down toward the actual ground. So you want the ground plane to be BELOW the antenna base, where it can reflect everything up in the air.
...talk of ground planes is pointless if you are topless...
No, it's not. You WANT there to be a plane, and you want that plane to be square to the antenna mast. So if the top's off, then the waves hit the cargo floor, the seat structure, the dash face, the w/s frame... That rough topography scatters them, making them less-likely to arrive at a receiving antenna clearly. They WILL still arrive, and they WILL still be clear to some receivers. But those receivers will have to be closer to you than they might be if you had a clean ground plane (like the hardtop or the hood) to reflect your transmissions farther. Is that distance critical? Depends on your situation.