Dear Tore,

> I question the wisdom of abolishing the need-based mechanism for
> sub-allocations exclusively, when (to the best of my knowledge) all
> other mechanisms to obtain number resources in all other regions are
> need-based.

Need-based princip make sense only until RIR has IPv4 for allocations. I understand that it was many years and it is as habit.

> > Just see how many transfers in other RIRs. This mechanism work not very good
> > for now.

> How come?
> In any case, if the transfer policy is broken somehow, why not fix it?

Transfers good for permanent transfer.

For temporary transfers better option sub-allocations while if you transfer IPs for some time than you get them back and see that they are in spamhouse and other black lists. In case of sub-allocation IPs in your control and you can regulate it. 

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Kind regards,
Alexey Ivanov
LeaderTelecom B.V.