The new Yeast book goes a little further than recommending a high fermentation temp for a starter.
For ale yeast, temps in the 70 to 80F should be OK. But for lager yeast, they indicated that lager brewers making large starters should step up the starter size incrementally and decrease the starter fermentation temp with each step to better acclimate it to lager temps.
So in the case of lager yeasts, I would say that you might want to keep those beasties in the 60 to 70F range instead of assuming more elevated temps.