I'm not sure what you mean from dummy-LIRs but I think you mean the ones that just set up to get a single /22 to transfer it, am I right? If yes, Yup It cannot keep "dummy-LIRs" from being set up, it just make it less attractive. exactly!
But
My argument was not about "dummy-LIRs set up", I'm talking about the LIRs that are not new and are already registered years ago, (before RIPE NCC starts distribution of last /8, before 2012) now if they apply to receive their last /22 why they have to wait for 2 years to be able to transfer them to others. (that makes IP distribution more difficult) Personally, I don't think any LIR that already has an allocation in the range of /19 or larger should even be allowed to get a /22 from the last /8 ... considering the trouble new LIRs have to get around with just a single /22, why shouldn't existing companies be stuck with what they have and think about conserving IPs a bit more? Also, if you e.g. already have a /16 (65k addresses), how much good do an additional 1024 addresses do you? Except maybe to monetize them by selling them off to someone who wants them ... So, in summary, keeping the restrictions on the /22 transfers up for both new and existing LIRs is more than fair ...
-garry