As some of us pointed out on another thread on this topic, keep bluetooth turned off when not using it (which is what most people do anyway for the exact reason you cited above) and one doesn't have to be concerned with this vulnerability.
It's a big nothingburger, IMO.
Most people leave Bluetooth _on_ all the time, because they’re not thinking about the technical nuances of marginal power consumption - instead they’d rather just leave it on for convenience.
The only Bluetooth disabling I do is ensuring the car’s stereo doesn’t try to connect to my phone. Having a conference call switch mics to the sound of momma yelling at the kids when she starts the car is...undesirable.