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Use meaningful variable names. ee does not reveal the semantics of your code. With no context I might interpret that as an ElementEnumerator. Why not write what the element should be — oNode or oTextNode for a text node element?
Test Your Assumptions
Dim oNode As Element Set oNode = ActiveModelReference.GetElementByID64 (3656) ' Be sure that we really have a text node Debug.Assert oNode.IsTextNodeElement
Understand the Error Message
The message box tells you that the element is not planar. I don't understand what a non-planar text node could be. It would help if you posted a DGN file that includes this problematic node.
