System-level power management has become a key technique to render modern wireless communication devices economically viable. Despite their relatively large impact on the system energy consumption, power management for radios has been limited to shutdown-based schemes, while processors have benefited from superior techniques based on dynamic voltage scaling (DVS). However, similar scaling approaches that trade-off energy versus performance are also available for radios. To utilize these in radio power management, existing packet scheduling policies have to be thoroughly rethought to make them energy-aware, essentially opening a whole new set of challenges the same way the introduction of DVS did to CPU task scheduling. We use one specific scaling technique, dynamic modulation scaling (DMS), as a vehicle to outline these challenges, and to introduce the intricacies caused by the nonpreemptive nature of packet scheduling and the time-varying wireless channel.