I assume you’re referring to the huddling behavior of emperor penguins. They don’t really “choose” for anybody to be on the inside. Rather, they clump up indiscriminately, and those that end up on the outside move around the edge, producing a slow churning motion, slowly working their way to the inside. It ends up being a process of rotation, where all of the individuals spend a little time inside and a little time outside — this way none of them freezes.
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