@turbomacncheese if the wifi headphones strictly follow 802.11b protocols then use it will be possible. But chances of it happening are close to zero, since pairing of head phones will be a problem and probaly add another stack to the protocol.
And in regards to the actual discussion. I really don't want bluetooth on the zune hd. Me personally i hate most bluetooth devices, as they either make you look retarded or when you are out an about looking for hardware to use it with it's a pain. For example how many outlets do you know that readily sells bluetooth headphones. After you answer that then ask how many people have you seen with a bluetooth stereo headphone. And then after you answer that then answer the last question on what the sales are for bluetooth stereo headphones. If bluetooth was to come on this zune hd as primarily for audio it will be a waste of money on microsoft part for it to be included. Now with the browser, yes they could have it since it could be a cheap netpad ( yes i said netpad, netbook is for something that is actually bigger and has about a 10 inch screen netpad just makes a lil more sense), but even with that most people will use the on screen keyboard more often.
So remember even though some stuff might be cool to have in a device it is not at all necessary, and as much as we hate to hear it. Microsoft is in this to make money, making money means cutting around edges, if your audience is about 10 million and you do a sample from them and find out that only 2% or less have a bluetooth enabled stereo headset, will it be a viable preposition to invest about 5-10 dollars more on a device knowing that only about 2% will use this feature. No you would not so you will have to cut it out and rather keep the cost down and make a higher profit margin on the device.