Answered today.
Quote:
Q81 Q. Is it legal to use either model of Victor speed controller or the new Talon speed controller without an attached fan, provided that adequate airflow is provided in some other way?
A. The only legal modifications to motor controllers are listed in [R65].
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My interpretation is that since the Victor comes with fans, it's not legal to remove the fans. Since the talons do not come with fans, it's legal to add fans per R65-D.