Hey, now wait a second. The declaration ROM must live somewhere, and that's usually where it was on those old cards, on an EPROM. I don't see anything else on the card that could be storing the card's firmware.
BTW, you should cover the window of the EPROM with a sticker or something. It's unlikely, inside a computer case, but too much exposure to UV will erase the contents of that chip and you only need to lose one bit, if it's the wrong bit...