Earlier quoted context omitted.
This is confirmed by the recent move of AMD towards extremely hot GPUs. You already see that in the most recent 290x, but they're talking about making hardware that is comfortable running at >100C. I'm not sure how relevant that is with regards to performance per watt, but I do know that heat is one of the most expensive (by-)products of electricity.
Isn't there some theorem of thermodynamics that says your device gets more efficient as the temperature difference between the hot and cold parts of the device increases? AFAIK the only reasons devices aren't run at arbitrarily high temperatures is that material properties change unfavorably, or you risk fires.
Or, approaching things differently, if you're only going to keep your graphics card for two or three years, there's no reason to let the fans spin up to an audible level until the chip reaches at least 80 degrees C.
Addressing a common misconception: fan speed/noise is not directly related to how much the graphics card is heating up the room by. Whether you run the fans at full tilt or you let the chip almost melt, the heat output will depend only on the workload.