I-07 Comment on FR Doc # 2012-17659

I’m Dr. Robert Carreira and I serve as Director of the Cochise College Center for Economic Research. I also teach economics at Cochise College and at Wayland Baptist University in Sierra Vista and Tucson, and I serve on the board of directors of the Bisbee Chamber of Commerce, among numerous other local boards, committees, and task forces. I am also owner and proprietor of the economic consulting firm Arizona Economic Research. There has long been debate over how much environmental regulation we should have—understanding that compliance generates costs. There is typically a tradeoff between economic growth and environmental protection, and the charge to policymakers is to strike the appropriate balance. The paradox is the more economic growth we have, the more environmental protection we can afford; but the more environmental protection we have, the less economic growth we may have—within certain constraints. I am not going to comment on what the appropriate balance is between protecting the environment and growing the economy, or whether this proposed regulation is appropriate, since there is no right or wrong answer. Rational, intelligent people can and do disagree. But one thing I do want to talk about is timing. We have heard a lot in recent years about the appropriate time to raise taxes, lower taxes, increase government spending, or cut government spending. We know the appropriate times are largely tied to the performance of the economy. For example, if the economy is doing poorly, it is typically not a good time to raise taxes or cut government spending. The same principle applies to regulation—it is generally not a good time to increase the costs of regulation during recessions or slow economic recoveries, such as what we are currently experiencing. The 2007-09 recession was the deepest since the Great Depression and the recovery has been the slowest since the recovery that followed the Great Depression. The costs of regulatory compliance are t