I have this same issue but it does not happen with every update which is even more annoying. Apple should disclose if the update turns airplane mode off before we begin the update process. If they disclosed it with some sort of pop up warning, we could choose not to do the update and avoid being charged for coming out of airplane mode. AT&T has been very understanding about crediting us for the times when Apple updates take the phone out of airplane mode, but it is, in my opinion, Apple's responsibility to notify us prior to initiating an update if this will happen. The updates check to see if there is enough battery life, etc. so they have some awareness of the status of the phone. It would not be difficult for the update process to notice the phone is in airplane mode and warn the users so we could opt out of the update.