George, This is not my understanding at all. If you create (in this thought experiment) surfaces at emissivity of zero, that means the surfaces don't emit. They emit nada. The only het transfer that's gonna happen off that (hypothetical) surface is from convection or conduction. Thus the "3" is totally wrong, since the emissivity controls everything. This is not just theory. Consider a thermos bottle or vacuum Dewar.
You can hold ln2 in these devices. Heat sneaks in via conduction, but the insulation suppresses nearly all transfer. Where did the 3 come from in that formula? s this a convection plus radiation formula? jb