Earlier quoted context omitted.
Yes, you'd still need a full forced air cooling system (especially with modern datacentre densities), so the only gain would be from the there being a higher temperature gradient for your heat exchangers to work with. There's no way that by itself would make enough of a difference to justify building a dc there, given all the other negatives that others have mentioned.
Actually modern datacenters, such as xAI's Memphis one, are now using liquid cooling since the power density of SOTA chips demands it.
It's certainly a far cry from opening some windows and stringing a few fans together in the hope that the chilly outside air will be enough to keep things cool!