This paper investigates heat transport in penetrative convection with a marginally stable temporal-horizontal-averaged field or background field. Assuming that the background field is steady and is stabilised by the nonlinear perturbation terms, we obtain an eigenvalue problem with an unknown background temperature
$\tau$
by truncating the nonlinear terms. Using a piecewise profile for
$\tau$
, we derived an analytical scaling law for heat transport in penetrative convection as
$Ra\rightarrow \infty$
:
$Nu=(1/8)(1-T_M)^{5/3}Ra^{1/3}$
(
$Nu$
is the Nusselt number;
$Ra$
is the Rayleigh number and
$T_M$
corresponds to the temperature at which the density is maximal). A conditional lower bound on
$Nu$
, under the marginal stability assumption, is then derived from a variational problem. All the solutions to the full system should deliver a higher heat flux than the lower bound if they satisfy the marginal stability assumption. However, data from the present direct numerical simulations and previous optimal steady solutions by Ding & Wu (J. Fluid Mech., vol. 920, 2021, A48) exhibit smaller
$Nu$
than the lower bound at large
$Ra$
, indicating that these averaged fields are over-stabilised by the nonlinear terms. To incorporate a more physically plausible constraint to bound heat transport, an alternative approach, i.e. the quasilinear approach is invoked which delivers the highest heat transport and agrees well with Veronis's assumption, i.e.
$Nu\sim Ra^{1/3}$
(Astrophys. J., vol. 137, 1963, p. 641). Interestingly, the background temperature
$\tau$
yielded by the quasilinear approach can be non-unique when instability is subcritical.