A lot of the time the cooling performance / noise just comes down to how aggressively the default fan curves are set to in the Vbios.
large picture mode i think you're right, up to a point, a better cooler can still help with temps and noise, i mean i was looking at a Gainward 4070, 83c at 36db with 195 watts, compare that to my MSI 2070 Super Gaming X which is a card twice the weight at 1.5KG: 71c at 31db with 220 watts, a very clear difference in cooling performance.
And you can still buy cards with just plain bad coolers on them.