I do not support this proposal as long as this is not cleared :
With regards to sub-allocations, I fail to understand what problem are you trying to solve? Isn't delegating resources downstream towards end-users (i.e., making assignments or sub-allocations) essentially the whole point of operating an LIR? Stopping LIRs from doing "LIR stuff" seems ill advised to me - or what am I missing here?
However I support the spirit of this proposal where allocation from RIPE and usage of IPv4 should be made harder. If IPv4 requires more work than IPv6 then perhaps we will see an increase in IPv6 usage (or I might be naive)
The proposal needs guidance to the NCC as to which specific /22 the NCC should de-register. The oldest? The least-assigned?
I don't think so. LIR might be free to give back any /22 it suits better. Denis