> but GPS data, wake my phone up, switch on the GPS radio, drain it's battery, send that data back... no. That wouldn't be legal where I live either, let alone expected.

Where does the article claim this turns on the GPS if off?

It .. probably does turn the GPS on?

While this is an important question, I don't see the sources mentioning it, what the standards mandate, and how the phones behave.

For example the wiki article https://en.wikipedia.org/wiki/Radio_resource_location_servic... describes the protocol as using the GPS and not as getting the location info from Android.