The interesting this is, those that will go on and on about the power efficiency but then overclock their card or cards and end up in the same neighborhood as the 290/290x.
ETA- The boost makes the GTX980 no where close to a 165w TDP card.
What else is new? That's the very essence for every enthusiast out there to push things beyond any boundaries.
How much does the Hawaii TDP increase for those enthusiasts that pushed their 290/290x beyond their boundaries? Now you have an equal metric to the above.