I am not an expert on this, and I have not checked with our experts, so one should treat this as the opinion of an amateur.
If I want to test drift and noise, I would do this in a case where I eliminate other sources of drift and noise. Considering this, I would use the dry cell to do this test.
If I work with a wet cell without flow, the noise may be ok, but depending on the design of the flow cell, a drift might occur as the cell warms up from exposure to the light energy.
If I work with a flowing stream, pulsations of the flow may expand the flow cell and create additional noise. Also, if I work with an automated mixing of the mobile phase, compositional ripples will affect the refractive index of the solvent and create additional noise, if the detector is sensitive to such things.
Actually, after writing this, I realized that the sensitivity of the detector to such miscellaneous events should be part of the evaluation. One can design detectors that are only minimally sensitive to such extraneous items. However, such tests are more useful for an evaluation of different detectors than for a performance qualification of an existing detector.