"Consistent"'s a tricky word, isn't it ... on it's own its actually meaningless, as you have no idea what that consistency is meant to be measured against.
My suspicion is that they've analysed some 95W rated coolers and found that they're only 95W capable at 100% fan speed, and typical fan profiles either won't hit 100%, or won't hit it at a low enough temperature. So to ensure adequate cooling in those circumstances they have to force the fans to ramp up earlier than usual, which means reporting a higher temperature than usual.
Interestingly AMD's own overdrive tool reports temperatures as margin to tjMax (or at least it does in the version on my laptop!), which is really quite disconcerting - watching a temp gauge rapidly drop towards 0 under load....