Because subcaps are all capable of killing each other happily. Rare cases excluded a frigate can kill a BS. And a BS fitted for it can kill a frigate. The active tank is not that different. Capitals represent a massive order of magnitude jump where you need a fleet of subcaps to take a single capital ship on. This means that to fight capitals you need capitals. That leads to super cap drops. And the only way to fight those is your own super caps.
That’s why capitals are treated differently.
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