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To be fair even the title says "may" in it. The context is that eyeball planets we're not actively considered, and climate considerations are a weaker rejection criterion for habitability. There is also a secondary result which is that systemwide habitability zones may be extended in the case of tidally locked planet by generating a geographically fixed planet-scale habitability zone. These are interesting results, even if they don't take into account the full range of factors contributing to habitability, it's just a message saying don't count them out on this one factor that naively might be considered exclusionary due to unfamiliarity.

Btw tidal locking can cause tectonic activity, as in the case of the Jovian moons.

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