If fail2ban isn't going to blocklist localhost, then it isn't a mitigation for this vulnerability because RCE implies LPE.
But, sure, in that case fail2ban won't mitigate, but that's pretty damn obviously implied. For 99% of people and situations, it will.
It's going to apply to the amount of servers that an attacker has low-privileged access (think: www-data) and an unpatched sshd. Attackers don't care if it's an RCE or not: if a public sshd exploit can be used on a system with a Linux version without a public Linux LPE, it will be used. Being local also greatly increases the exploitability.
Then consider the networks where port 22 is blocked from the internet but sshd is running in some internal network (or just locally for some reason).
It doesn't matter if 99% of the situations you can think of are not problematic. If 1% is feasible and the attackers know about it, it's an attack vector.