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So if he were using an old cellphone, before the days of apps, would he still have been served a notice from the phone company for his phone tower location?

The article says: "drawn from users’ GPS, Bluetooth, Wi-Fi and cellular connection"

and cellular connection.

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_That_ is the question we should be asking. If not, is it because geofence warrants have a higher legal bar if issued to a phone company? Or is it about the level-of-effort?

Cellular location data is not nearly as precise as GPS. A cell tower could serve an area of many square miles (the fewer users there are in the area, the larger an area the tower can accommodate), so just knowing which cell tower you're talking to can't place you at a particular address.

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