Well, I am another EVGA 3080 Ti FTW3 disappointed buyer you can add to the list. The card almost never breaks 400w even under stressful test conditions that pull other cards to that limit. It is not "normal" behavior, even if it does sound nice (or sound true) to say that cards "don't need to stay operating at the very limit just because that is the stated limit". That might be true, but the behavior of these cards in the past is that they DO operate close to the power limit when your power limit slider is at 100%. And when you have a bios that goes beyond 100%, the average power draw goes up!
Not so with these cards, and I would say it is a defect. I even have voltage headroom (supposedly the voltage limit is 1.09v on these) at like 1.05v when hitting the 400W power limit. So my card NEVER goes beyond 1.05 or so, even if I lock the voltage higher in Afterburner. This is because its hitting the 400W power limited sooner than the voltage limit.
I wish EVGA would release a BIOS with this fixed. But, since they are no longer in the GPU game, they probably will do nothing. I consider it to be false advertising. The reason I got this was because of the stated power limit of 450W lending to better overclocking headroom. Well, based on what I've seen others go through when discussing this with EVGA, it seems like pretty terrible and apathetic customer service.