That's if they were relying entirely on convection, I think FrankHahn's point is still valid as the fan only has to make up for what the natural heat rising can't do.
In building my storage enclosure I've tried to mimic a similar principle by keeping the PSU at the bottom...
But, since the PSU exhausts air - doesn't that mean it's pulling cool air out of the bottom of the case, instead of pulling warm air out if it were at the top?
I like that the 120mm fan in my PSU at the top of my case is pulling warm air out of the case.