By (i) highlighting the mitigation effect of strain rates on laminar flame instabilities and (ii) comparing peak growth rates of laminar flame instabilities with strain rates generated by small-scale turbulent eddies, a simple criterion of importance of the influence of the instabilities on an increase in premixed flame surface area in turbulent flows is suggested. The criterion implies that, even in lean hydrogen-air mixtures, laminar flame instabilities can significantly affect the flame area only in weak or moderate turbulence (the Karlovitz number defined using laminar flame speed, thermal flame thickness, and Kolmogorov time scale is on the order of 10 or less under room conditions).