Miller et al. (2005) assert that the estimate of White et al. (2005) of 1.94% of eastern Colorado being occupied by black-tailed prairie dogs (Cynomys ludovicianus) was biased high. The subsequent surveys conducted by Miller et al. (2005) do not provide a valid bias correction for the estimate of White et al. (2005) because 1) their survey protocol could only result in estimating a negative bias, with no possibility of estimating a positive bias; 2) their nonrandom selection of intercepts did not provide valid inferences to the sampling frame used in White et al. (2005); 3) evidence suggests that they did not survey the same aerial tracks as surveyed by White et al. (2005); and 4) their surveys were conducted 2 years after the original surveys, thus not comparable given the temporal dynamics in prairie dog colonies.