Yes.
(post too short extender)
I might as well expand.
As with all conventional cooling methods it is impossible to reduce the heat of an object to lower than the ambient temperature via convection. Every heatsink has a rating of how much heat energy it can move in a certain environment within a certain time frame. Raising the base temperature your material has to work with doesn't necessarily reduce its efficiency but if you are trying for a target temperature it will fudge your numbers.