The Basel Committee has attempted to reduce procyclicality effects in the new framework, incorporating factors such as estimates of loss severities that focus on downturns. These are wise decisions intended to obviate the need for institutions to raise large amounts of capital at the trough of a downturn - something that can be quite difficult and add to financial market instability.
But I think we could all agree that Basel II should not be unresponsive to changes in risk, for example when the obligor rating distribution at an institution shifts to poorer-quality borrowers. In my view, we want these signals of changes in risk reflected in regulatory capital levels.