Actually what make him confident are his tests of an early sample, that s what he explicitely state.
Now he measured 93W on the 12V ATX rail, wich accounting for losses makes about 82W for the CPU, but he dont know to what extent the chip was overvolted since this is an ES and an early one.
If we take his number of 82W as basis and the fact that he state that the chip did turbo to 3.3, at least occasionaly, and that it s at this frequency that he indeed measured those 82W max power then he s uncautious to pretend that the chip exceed 95W at 3.6 (he didnt state the frequency@95W+..), because the chip wont consume significantly more than at 3.3, expect something like 20%, so if there s an excess it s a couple watts, and still, likely due to a slight overvolting..