Small update: For the last year or so I've been working mostly on Windows and the fan has never shut off. Today I spent some time on Linux and the silence just struck me. The fan was actually off!! So I whipped out the kill-a-watt and I checked that Linux in idle (all programs closed) consumes 18.1-18.3 watts, closing the lid reduces that by 4-4.5W. Next I rebooted into WinXP and it just won't get below 23W with the lid open.
So Windows is actually producing about 5 watts of heat more than Linux, just in idle
And that's why I keep hearing the fan. I even took the laptop down to the basement and left it there for a while to see if the 5°C lower ambient temperature is enough to turn the fan off. Nope.
It looks like getting a new computer is more likely at the moment than reinstalling both OS's, so until then I'll just have to deal with the noise.