If they compared two different cards (in attempt to figure out about the power consumption) to each other and the only difference was the cooling solution, that was a wrong way to go. The right way would've been to test both cooling solutions in both cards and measure. Twice. Most probably most of the difference was due to better bin GPU and better bin VRAM. But sure temperature does play a role in power consumption of a chip, there are many other factors too, which vary from card to card.
It would be quite interesting to see accurate measurements though.
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