Thanks @cancerrat. I made sure the fan curve control was enabled.
I think I might have solved this by increasing the airflow in my computer case - added an extra exhaust fan and adjusted the exhaust fan curve in my bios to blow more air through. I confirmed that the GPU Fan control was working by manually turning it off/on in Precision. Then I opened the case and the weird full-RPM cycling stopped so I think there wasn't enough cooler air flowing through the case.
My hunch is that the GPU has some sort of fail-safe either by some other temperature sensor I can't see or maybe an algorithm that determines if the fan speed isn't bringing down the temperature as much as it should be.
Feature request for EVGA/Nvidia - somewhere expose when something else takes over fan control...
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