All else being equal (fans of the same diameter and same maximum speed), I always thought non-PWM fans were known to be capable of spinning slower. Maybe that's no longer true.
In my Fractal Design Define Mini, with an ASUS motherboard, I have the original two Fractal Design PWM fans in front and a Scythe PWM fan in the rear, all controlled by 4-pin headers on the ASUS motherboard. Works incredibly well. All of them are approximately 1300 RPM fans. Below about 850 RPM I don't hear any of them, so it's not necessary for me to spin them at their absolute minimum speed.
Maybe I said so . . . I have the standard CM 200mm LED fan in front-panel, an NZXT 200mm in side-panel. Those are 3-pin units. Then I have an Akasa Viper 140 PWM in the middle of my NH-D14 pipe-and-fin towers, and a Gentle Typhoon AP-30 PWM at rear exhaust behind the D14.
Currently at idle, the 200mm fans are at 343 and 848 RPM respectively. [The NZXT tops out at 1,300]. the Akasa (idle) is at 680, and the AP-30 at 1577 RPM.
At CPU temps above 65C, they all go to 90% of top-end: 600, 1,200, 1,500 and 3,850 RPM respectively. The first three fans are barely noticeable even then, while the AP-30 can be heard, although the acoustic mods around the AP-30 make the noise level quite acceptable -- mostly muffled white-noise.
I honestly can't hear anything. IMHO, the concerns about how slow you can get one type of fan to spin as opposed to another isn't any earth-shattering or fundamental issue. Because of my "fan-curve" customizations, the reduced airflow at idle has raised idle temperatures by a few degrees -- to ~ 35C. But if you can't hear anything, a few RPM here or there wouldn't matter . .. IMHO . . And neither would idle temps averaging 35C.
Now . . . it's true that my ducting with the AP-30 still shows average core MAXIMUM load temperatures at ~73C (room ambient 77/78F). That's with a 4.7Ghz over-clock. Another member with an i7-2700K says his CPU peaks at 50C @ 4.8Ghz, and he's using a Corsair H110 AiO cooler.
But if the issue has been equally about noise, my system is more quiet than any H110 would show. And that's with an AP-30 running 300 RPM below the full-bore 4,250.