You can do it with ZFS at least. I have a ZFS setup which idles drives. If I don't access the datasets on the drives, they don't spin up. You do have to be careful with things like auto snapshotting tools though - that will typically wake drives up. I had to script mine to only run on relevant datasets when drives are spun up and also had to edit the tool (sanoid) to prevent it from enumerating the list of snapshots on the idle datasets not being snapshotted.