my understanding is that when the engine is up to temp, its within a predictable range, because the cooling system is designed to keep it there. when it's cold, it can be 70 degrees out or 0 degrees out - both are considered "cold" but potentially big swings as well. doing the valves hot has never been a problem for me - just have the few tools necessary all at the ready, car in neutral, pull the plugs, pop the valve cover and check/adjust as you go. i turn the cam with a big crescent wrench at the bosses to get lobes up. i start at #1 and things are still too hot to handle when i get to #6. interestingly, i've always found a few tight, a few loose when i do a hot adjust after a cold one, but when i've done a hot adjust and check later on (after running a few days) it's always been spot on. i adjust to snug fit, where the next size feeler gauge won't go in.