Displacement and Acceleration
Arrays of satellites cannot maintain a constant displacement above or below the orbital plane without a constant (and significant) acceleration keeping them there. The ΔV needed over the lifetime of a satellite is beyond the range of high Isp engines. Further, it is unnecessary; by using constellations that evolve and rotate in three dimensions along the orbit, the same results (high gain main lobe, suppressed sidelobes) can be achieved. It is important to work with orbital mechanics, not fight nature and physics.
Imagine an attempt to permanently "hover" on the "north" side of a circular equatorial orbit. All Kepler earth orbits are mapped onto planes which intersect the center of the earth, and our hovering object is actually on a different, slightly inclined orbit. If the object is free to follow the orbital mechanics without an external force, it will follow a slightly different inclination circular orbit that intersects the original orbital plane.