I've made a little progress diagnosing it.
BitLocker Drive Encryption Service - randomly scans HDDs periodically. Only needed when unlocking drives, so you can stop it after boot up and unlocked drives remain accessible.
Diagnostic Policy Service - I don't know what this nonsense does but it wakes up HDDs regularly. I disabled it and nothing bad happened. It seems to be related to network connectivity, so I have no idea why it accesses my HDDs.
Micorsoft Anti-Malware, or whatever it's called now, randomly scans drives that haven't had any disk activity, for no reason. Even if you add an exception for them to it, it just ignores you and accesses them anyway. It might be because the exceptions are path based and it is not considering the path for those accesses.
Related to that, MsMpEng.exe likes to wake up hard drives for no reason too. It appears to be some kind of system file integrity checker.
For some reason the Shadow Copy Provider service accesses drives periodically. Disabling that could be bad.
There's more to it, but the bottom line is that too many parts of Windows like to randomly access your hard drives at random times. There is no coordination, and no attempt to check if the drive is active before doing it. Whatever caching is in place is inadequate.
Basically Windows 11 hates hard drives and loves drowning polar bears. The only solution is a Linux NAS for hard drives, and SSDs only for Windows boxes.