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There are numerous subtle and less-subtle biases in distance measurement; see [213] for a blow-by-blow account. The simplest bias, the “classical” Malmquist bias, arises because, in any population of objects with a distribution in intrinsic luminosity, only the brighter members of the population will be seen at large distances. The result is that the inferred average luminosity is greater than the true luminosity, biasing distance measurements towards the systematically short. The Behr bias [12*] from 1951 is a distance-dependent version of the Malmquist bias, namely that at higher distances, increasingly bright galaxies will be missing from samples. This leads to an overestimate of the average brightness of the standard candle which becomes worse at higher distance.