>>11963761>subsurface oceansThey don't even need to be subsurface. Ocean worlds shouldn't be that uncommon, and its as good a filter for radiation as you could hope.
The problem is if you're an aquatic life form its going to be tough to become a technological species since you can't harness fire, which is the base skill in the tech tree.
Also flippers aren't the most dexterous appendages so if you want to have the ability to manipulate tools you need some special hoops to jump through evolutionary speaking.