I have a little bit of experience with HDD's and cooling... Out of the 10 or so HDD's I have in the office right now, you don't really need a cooler if you run single drive config..
With raid, I think it's better to have coolers. I striped a raid 0+1 on 2 40gb hard drives just for the hell of it, and it seems that the HDD's run at full throttle 100% of the time, and it made my case around the hard drives too hot to touch... So I touched the 2 raided hard drives and they almost burned my hands... A few months later, one hard drive crashed.
In conclusion, I think if the hard drive is not too hot to touch, you don't need a cooler... Sounds really stupid, but it's even more dumb to put a fan on a hdd that doens't need it...