Exactly. Which is why I don't see much difference in most of the scenarios jamieb describes, except for 5.
In our current office, we don't have the luxury of closed offices, but we do have separate spaces (kitchen, meeting room, small "lounge" room, hallway.) So the informal rule is: the big open room where everyone sits is on the maker's schedule, if you have to big discussions or use the phone, go elsewhere.
Works well enough most of the time. Of course it helps that there are very few non-programmers, and those are out of the office most of the time, so the open plan office is usually peaceful anyway.