Dear Team, 

Congratulations on tackling this difficult issue. I'm thrilled to see it on the docket as an important topic for FAO, and I am very appreciative of the opportunity to read the paper and respond.

1. The current primary forest definition is not adequate for North America if we wish for the variable to be comparable in a globally meaningful way. The definition is vague without discreet measurable parameters for various biomes, leaving it largely up to interpretation of each of the correspondents to locally define the variable. While that is "fine," it means that data point is not useful at the global scale, which is the purpose of the FRA data, in my opinion. In particular, I have some of the following concerns: a) The use of the word "natural" allows for a wide range of "degrees of naturalness" to be included in the primary forest category. For example, are forests that have grown over aztec ruins considered natural? Are they Primary or Secondary? Young forests can show natural forest dynamics, natural tree species composition, and natural age structures.  b) It seems the primary concern of FAO is commercial logging operations or other commercial use (as is evidenced by  the use of the terminology "no human intervention EXCEPT native people living native lifestyles"). How far back do we go to determine who is "native" or "indigenous" to an area, and how large can their disturbance for "traditional use" be before it becomes large enough to be considered human intervention? For example, in the United States, native Americans used fire broadly to manage forests - and to eliminate them - would that have been primary forest, still?  c) if we use the approach of remotely sensed data to create a metric representing "primary" forest, I'm still not exactly sure what it is we are measuring. Are we measuring ecological function? Because some "primary" forests are likely less biodiverse or less beneficial to humans/wildlife than well-managed secondary forests. Are we measuring human footprint? Because if so, native and indigenous populations ought to be included. Are we measuring growth stage or structural complexity or species composition? Because those things are not meaningful on a global scale. If remotely sensed data shows "greening" and "heights", what about in areas where the canopy is preserved and there is an understory that appears structurally mature, but it consists of nonnative species and/or planted agricultural crops?

2. Yes. I do not understand why there isn't some space given to the "WHY WE WANT THIS" question. There are lots of discussions of who has said it's important and what definitions various groups have adopted, but not a whole lot of "here is the question we are asking and why we are asking it."  Also, I have yet to see a good explanation of why human impacts are measured UNLESS it is native populations. Who cares if the disturbance is commercial or local if the impact is the same?  What if it's commercial exploitation by indigenous peoples? I don't mean to be obtuse, but I do not understand this exemption of "native people." People are people.  Perhaps it could be reworded to exclude particular USES by ANY people - e.g., not including low-impact uses like gathering pinecones for decorative purposes or gathering firewood for local use.  b) in the section of ecological characteristics, line 208, there's discussion of native species composition and natural levels of biodiversity. How native? What level of naturalization is necessary before something is native? At what point is something considered naturalized included in the "nativity" of the forest environment? Is there some scale or percentage of naturalness that a forest need meet before it meets the "natural level of biodiversity" and what is the baseline by which that is measured? When considering "biodiversity", we find that oftentimes disturbed forests are more biodiverse than undisturbed forests - so, not all biodiversity is necessarily desireable biodiversity. To what time period to we refer to determine what level of biodiversity is optimal?  

The source for US NATIONAL REPORT statistics is NOT Alvarez et al. Please correct.

3. The US uses the protected area database IUCN categories 1-5 as well as national parks, interior Alaska, wilderness areas, and other roadless forests.

4. We need a discreet understand of what the information is to be used for - what is the purpose of knowing the area of "primary" forest and how is it beneficial to the global community? Is the goal to re-establish or maintain some specific area of "primary" forest, and why? Someone define the question and the reason for the question, please.  I think that most likely the idea of primary forest is best addressed at the biome level rather than the global level in order to be meaningful.

5. Countries need very discreet, measurable characteristics in order to provide something useful to the environmental community, as well as a clear understanding of why the variable is important and how it will be used.

Thank you, and here's to a productive meeting in March.

Sonja Oswalt