It really isn't so much about the CFM as it is about the temps, and making sure that a fan failure is handled appropriately. Idle hard drives and busy hard drive both burn substantial amounts of power.
The best way, by far, to manage fan speeds is to have a decent mainboard that is handling that aspect of things for you. A good quality board will ramp fans up and down as needed, and IPMI on the board can help monitor for a failure of the fans as well.