Passive pneumatics and 12 motors?

The following question is based on the premise that a reduction in total number of motors allowed when using pneumatics assumes the actuators are being used to deliver a force on a load as an alternative to motors. If a pneumatic system installed on the robot is passive (not controlled by the cortex), can a team still use 12 motors?

Example: A passive pneumatic system that consists only of a tank(s), hoses and cylinders acting as dampeners or shock absorbers in a closed loop. The system has no valves or other cortex-controlled devices that operate the cylinders or manipulate the passage of pressurized air in any way, shape or form.

As this question pertains to Competition legality, it should be posted in the Official Q&A:
https://www.robotevents.com/VRC/2018-2019/QA