Im not gonna use smeargle lol
also anyone with half a brain or more should know physically defensive has more defense, otherwise they shouldn't be playing pokemon
also I don't rly understand the spread for tank Ho-oh, but 120 SDef EVs allow it to survive +1 252 SAtk Arceus after sr guaranteed, while 128 allow it to guarantee its survival against 252+ dialga's meteor after sr
"Whirlwind allows Ho-Oh become a great phazer, but this is generally better left to physically defensive Ho-Oh which has more physical bulk."
are you sure physically defensive Ho-Oh has greater physical bulk, pretty sure it doesn't :p
also if smashpass smeargle carries protect it can't fit ingrain :D
max physical defense is still usable, don't listen to them, Impish Skarm with no SpD works in ubers, you just can't switch in on Spacial Rend or Draco Meteor that well or tank Ice Beams. In exchange you get to beat SD Groudon and any SD Arceus