Depends, actually. That is true for some setups (more modern, I
guess?), however there are already plenty out there who have either
less advanced controllers or no controller at all. For example, NOR
FLASH can be directly mapped to memory (its interface is ROM-like:
address lines, data lines, control lines), and on many embedded
systems it is tied directly to the addressable memory space. That
doesn't have a controller and requires a good filesystem in order to
prolong its lifetime...
I have this older headless PC which actually has a 256MB NOR flash
chip (with no controller) where it stores Win CE and uses a
proprietary filesystem which apparently does this shuffling.
