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There seems to be good reason to think that most aliens inhabit eternal darkness in a ocean underneath a global ice cap.

"New research by scientists from NASA and Japan’s Osaka University suggests that rogue planets – worlds that drift through space untethered to a star – far outnumber planets that orbit stars."

https://www.nasa.gov/missions/roman-space-telescope/new-stud...

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GP was precise in their phrasing: "aliens we could cross paths with". It would be much harder to actually meet or communicate with aliens that live in a dark ocean on a rogue planet than it would be for other aliens. ;)

That would limit the available energy inputs though, miniscule solar radiation, miniscule tidal forces, so unless you've got active plate tectonics or radionuclide decay, it's all going to become ice, presumably?

There's some truth to that. Europa, Enceladus, and other places are more than frozen ice balls because they get tidal heating from orbiting a gas giant. Even so, there are probably vast amounts of rogue gas giants between the stars. The very largest of these objects are known as brown dwarfs.

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