  Recent calculations using non-linear relativistic cosmological perturbation
theory show biases in the mean luminosity distance and distance modulus at low
redshift. We show that these effects may be understood very simply as a
non-relativistic, and purely kinematic, Malmquist-like bias, and we describe
how the effect changes if one averages over sources that are limited by
apparent magnitude. This effect is essentially identical to the distance bias
from small-scale random velocities that has previously been considered by
astronomers, though we find that the standard formula overestimates the
homogeneous bias by a factor 2.
