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According to description of the achievement you can get it on specific tiles which appears underwater and also on deepling area of gray island, but as the area doesn't require any drowning protection, I'm not sure about this. Has anyone tried and verified this?

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No, it has been confirmed that Fiehonja doesn't count for Deep sea diver achievement.

Basically, every underwater area that deals drowning damage will count for it, good luck (:
by (171 points)
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Thanks for answer :)
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It should probably be mentioned that not every underwater area counts as long as you are taking damage. Research shows there a specific tiles that will count. "Confirmed working tiles are Ocean Floor, underwater ‎Marble Floor and underwater Sandstone Floor. Lava crack tiles in the Sea Serpent Area are not counted, as those are also used on land."
Source: https://tibia.fandom.com/wiki/Deep_Sea_Diver
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