To clarify, i reread, and the article does say they are buying the data from Fog Data. I’ve read elsewhere that Fog Data logs location data from installed apps using location services. I don’t know if that’s the only method Fog Data uses. If it is, turning off location services should significantly impair this approach. Airplane mode would not, though it would probably prevent radio triangulation like you describe.

My comment was that there are a lot of ways that phones record location data, and no single countermeasure stops all of them. In addition to apps using location services, the phones themselves track you in a lot of different ways. For example iPhones continuously monitor and log location data even when the phone is off. They use BTLE mesh when other methods are unavailable.

The article doesn’t say what methods the police in NV are using, so it might be effective against that particular approach, but in general, airplane mode doesn’t prevent phone tracking.