Habitability of brown dwarf systems

The habitability of brown dwarf planets is considered less plausible than for main-sequence stars, due to the cooling central dwarf and tidal forces due to super close-in HZ, but more plausible than for white dwarfs due to the lesser XUV and X-ray output. The planet would have to have an extremely low orbital eccentricity (ranging from Earth-like to ten-millionths depending on semimajor axis and brown dwarf mass) to avoid a tidal runaway greenhouse effect, and a planet's water and atmosphere may not survive the early stage when the planet is interior to the HZ.