Nikon provide a pictures remaining count at worst case. JPEG compression is very variable, a totally white or black (noise free) or any simple image is compressed into a smaller space using the JPEG algorithm. More complex scenes such as grass or tarmac is not compressed as much due to JPEG being efficient with large areas of minimal detail. Aviation shots tend to have large areas of detail free sky so can be compressed well.
The counter will continuously update so if it shows 200 remaining and then you take a 10 aviation shots it may read 10 recorded and 197 remaining.
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