Only if you're not designed for it. We've got a 48U rack running 73.5 kW at our datacenter on pure air cooling with no trouble. It has 15 SP35s and 7 SP30/SP31s. The idea that you have to go to water cooling in order to achieve high densities is both expensive and false.
You are correct. It's not that we couldn't do a max density air cooled solution. Spondoolies already does this. It's that our architecture is designed to be upgradeable. Some design concessions had to be made.
Water cooling also opens up the hottest parts of the world to mining. We can easily handle 40c+ ambient air temps. And have tested to 70c exiting water temps if so desired for industrial waste heat usage. Higher temps may be possible. With a serial power design this will easily be achievable.
-Nathan