In his skewering of stepwise regression, Frank Harrell mentions that the usual $R^2$ is biased high (I assume when it is calculated as the usual adjusted $R^2$ with the number of parameters set to be the number of parameters that survived the stepwise selection).
That sounds pretty bad, but we use biased estimators all the time. Ridge regression, for instance, leads to biased parameter estimates, with the hope being that the reduction in variance is so much that the mean squared error is lower, despite the bias.
Thus, a biased estimator is not a dealbreaker.
If the stepwise regression $R^2$ estimate converges toward a high-biased value, however, then that inconsistency seems like a dealbreaker.
So is stepwise regression $R^2$ estimation just biased or also inconsistent?