I used an old cooler with no top that my Carboy fits in, when filled with water it goes up a little more than halfway up the Carboy, stick a couple frozen water bottles in and monitor the temps twice a day, in a cool dark room, it's worked like a charm, swamp cooler! Some even take a Tshirt or towel and cover the Carboy leaving some touching the water to further help with cooling.
Cheap, efficient, effective way to ferment any ale. As for your question specifically I can't answer, but I believe it more depends on the yeasts range of acceptable temps.