People want the option to make their laptop silent or nearly silent. And when users do need the power, they generally prefer a slightly slower laptop at a reasonable volume rather than the roar of a jet engine.
Laptop manufacturers want their devices to score high on benchmarks. The best way to do that is to add a fan that can become very loud.
The incentives are not aligned.
All laptops should be designed to operate passively 100% of the time, if the owner so chooses. I doubt manufacturers will go that route unless Microsoft nudges them towards it. It would have downstream effects on how review sites benchmark laptops (i.e., at various power draws/noise levels producing a curve rather than a single number), which would have downstream effects on what CPU designers optimize for. It'd be great for consumers.