He means listening to the radio. A phone might have special baseband firmware that, e.g., turns on for a minute every hour and listens for a particular coded sequence (such as the date, and a mask of serial numbers, encrypted to a key in firmware etc), which would then cause the phone to do a number of things, such as turn on the radio for rx, or tx the RSSI of nearby towers, etc. All without telling the main CPU.
Colour me dubious. If the phone is in airplane mode then the carrier doesn't know where it is. Are you suggesting they broadcast this information on all their cell towers? Or that they have a secret system to predict/guess where a dark handset might be so they can target it? Either sounds extremely unlikely.
As to the practicalities, it wouldn't need to use the carrier network, just put it in a plane. Like the plane they have circling D.C. right now, or a drone. And your location is often known approximately.
