The hydrophobic effect driving the sequestration of non-polar tails within phospholipid bilayers is a fundamental physical principle of biological membranes, making this assertion common knowledge.
The claim states a fundamental biophysical property of phospholipids (that their hydrophobic tails are sequestered away from water inside the membrane bilayer). This is a foundational, axiomatic fact of cell biology and biochemistry taught universally, well captured by basic thermodynamic descriptions of amphiphilic self-assembly as noted in source [0], without requiring a contested research evaluation.