The low‐frequency theory of surface scattering, as suggested by Biot for a nonuniform distribution of bosses, predicts both specular and nonspecular scattering and permits a calculation of the (incoherent) scattering strength. It is found that the scattering strength predicted by this variant of the standard Biot theory is independent of frequency for sufficiently low grazing angles. This is to be compared with the low‐frequency limit of perturbation theory that predicts af4dependence for all grazing angles. It is a well‐known empirical observation that the scattering strength for the seabed is independent of frequency (or weakly dependent on frequency) for low‐grazing angles. This leads to the postulate that scattering from the seabed at low‐grazing angles may be due to small‐height, large‐slope roughness elements, such as considered in Biot’s theory of surface scattering.