Hi Tore,
The way I see it, this argument applies equally well to LIR->EU assignments, and to {LIR,EU}->{LIR,EU} transfers. I don't understand what makes sub-allocations special here.
It would IMHO be much more interesting to see a proposal that would retire the needs-based principle completely for all forms of IPv4 delegations (that aren't taken from the NCC pool). Does it really serve any useful purpose nowadays?
If some LIR wants to give away (assign, transfer, sub-allocate - whatever) all their remaining free space to someone who doesn't really need it - why not let them? It won't impact me or anyone else since their wasteful spending can no longer translate into an increased draw from the shared pool. I, on the other hand, would certainly not miss the assignment request documentation bureaucracy.
Call for feedback: I am very interested in how the working group feels about such an idea these days now that the normal RIPE NCC IPv4 pool has run out. Thank you, Sander Steffann APWG co-chair