Myself and a friend have been throwing this idea around for a while now, and we came up with a different variant on it:
1. Snorkel speed IS NOT surfaced speed, and in all reality, needs to be LESS than submerged speed (snorkel runs the risk of breaking off of a sub at higher speeds...)
2. Snorkel restores air SLOWER than if you are surfaced, cause seriously, it's a snorkel, not opening all of the hatches on the sub and drawing air in.
3. A sub at snorkel would be spottable at close range by ships without sonar AND by scouts.
4. Subs at snorkel would still be vulnerable to taking splash damage at the very least, which can get pretty high depending on what is hitting it. Otherwise, it's not all that unlikely to imagine a 16" shell hitting a sub that's just a few feet below the surface.
Therefore, there would be reason to not use the snorkel (slower speed than submerged speed, slower air recharge than surface), but there would also be a counter to it (spotted by EVERYTHING, able to take damage from surface shells).
That's just the concept that we came up with.
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