Perhaps you have a different meaning of the word energy? It will certainly take less radio energy to do what I suggested.
And as for GSM, have a look at http://mobile.slashdot.org/story/09/08/17/0014235/Open-Sourc...
Perhaps he interpreted your comment to mean "less energy for the hacker to build" rather than "less battery power for the device to operate."
Even without the encryption, it is extremely difficult to demodulate a GSM signal