Are any SATA SSDs actually built to sink heat into the enclosure? e.g. The 860 Pro released in 2018 has a PCB taking up a third of plastic enclosure with no heatsinks to speak of: https://www.myfixguide.com/samsung-860-pro-ssd-teardown/

And even in worst-case hammering of drives, thermally throttled NVMEs can still sustain higher speeds than SATA drives.