I honestly can't see why a card thats only 40-50W more, spread over a 50% larger surface area would run "that" hot. AT the end of the day where they read the temp from can dramatically change the temp, which is a largely irrelevant number anyway.
If they read the temp next to a 650Mhz clocked rop, or a 1,7Ghz clocked shader will probably give you different numbers, but realistically, unless the cooler is horrible badly designed I can't see why it can't cope with the extra heat output with a 50% larger area, it "should" have a quite a bit lower power for any given surface area than a 58XX series chip and as we've seen with the 5970, a heatsink that can shift 225W is well, incredibly easy, the 5970 sink can cope with a 400W load.
Temp's shouldn't be the Fermi's problem in any way at all, price, yes, temp's, no.