What's going to matter for audio streaming in an automotive (the case they are concerned about) is the energy consumption in the receiver, not the transmitter. They are measuring the second.
Who cares about power usage of the receiver in a car? It's got access to the 12v alternator/battery and as long as it turns off properly hen the car is off, radio power is going to be negligible compared to moving the vehicle, nevermind things like air conditioning, power steering, headlights, etc. Otoh, the transmitter in your pocket might not be plugged in, so that's important.
Believe it or not I don't have a smartphone and find my life is perfectly meaningful w/o it (e.g. there is nothing convenient about using cellular streaming in my car if I have to drive a few miles from home for it to work.) so I was thinking about streaming from the car audio system to headphones and not the other way around.
But generally it is the smaller, more mobile device which is going to have battery problems, which is going to be the phone if you are streaming from a phone to your car.