I actually find myself asking people to count calories less and less if for no other reason than ... they can't count! Even registered dieticians underestimate their own caloric intake. Of course when somebody's a tub of goo the margin of error is greater when you tell them to, say, reduce to 1,500 calories.
Interesting note on NEAT: as people lose weight NEAT tends to decrease. It may be wired-in. Regardless, just another reason why some would say that exercise is actually more important during the latter stages of weight loss and also for maintenance purposes.