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Well rhere is cool and there is "cool". Typically, a DSLR internal processor and battery produces most of the heat retained inside, and that will certainly be higher than outside air temp. If you are going to cool a sensor it should be done to the sensor directly and that requires a TEC and a cold finger to work best. Cooled DSLRs can be expensive, but some perform very well if you can get them down to 0C (the sensor temp). A cooled astro CMOS camera can run sensir temps to -45C below ambient, some CCD cameras achieve even cooled thresholds. Software noise reduction is never preferable to a cool sensor in my opinion, and noise takes several forms. Noise removed by cooling is only the thermal kind, and a well built astro camera will, today, have low read noise as well.
I have run stock DSLRs, cold finger cooled DSLRs, and dedicated deep cooled astro CMOS cameras, hands down the later performed the best for both thermal and read noise. This is my opinion.
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