Hi David,
current policy does not allow PI transfers, you do not own these resources, and you should let them be reclaimed by the RIPE NCC if they are no longer in use. As a LIR, you should know this and be able to communicate it with conviction. You may charge consulting fees in the process ;-)
Actually, that's not quite what the policy says. Perhaps I'm nitpicking, but I think that the difference is significant, even if it is small. For reference, policy says: «All assignments are valid as long as the original criteria on which the assignment was based are still valid and the assignment is properly registered in the RIPE Database. If an assignment is made for a specific purpose and that purpose no longer exists, the assignment is no longer valid. If an assignment is based on information that turns out to be invalid, the assignment is no longer valid.» My point is that «no longer in use» isn't the only thing that would invalidate an assignment. It might still be very much in use, but as long as it isn't used for the same purpose it originally was, then the assignment is invalid, according to policy. This is echoed by the suggested PI contract, which mandates: «The End User shall use the assigned Independent Internet Number Resources solely for the purpose as specified in the request on the basis of which the Independent Internet Number Resources have been assigned.» These requirements are in my opinion out of touch with operational reality; networks evolve and change over time, and given enough time, pretty much all assignments made will end up being used in a different way than what the original criteria was. The PI assignment request form asked for an very detailed criteria, with a breakdown of each individual subnet in the network, and a listing of all the equipment that would be used, including the manufacturer name and model numbers. So if you in the 1990s received an assignment that you had said was for a dozen brand new Sun UltraServers, you better not have replaced those with modern x86 hardware, or you have invalidated your assignment! :-O Some NCC staffers have told me that the way they've logically "solved" this impossible requirement was to consider that whenever the criteria/purpose changed, the original assignment was returned, and a new one consisting of the same block was issued for the new purpose. Then they could just "optimise out" the middle steps where the assignment was removed and re-added. That approached worked (up until Sep 2012 anyway), but I think it would be much better if the policy didn't worry so much about the "original criteria", but rather focus on whether or not the assignment conforms to the address policy in effect at any given time. If it does, there is no reason to call it invalid. Tore