Andrew D. Myers

March 24, 2006

VIA EDGAR

Securities and Exchange Commission
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549

Attn:    John Reynolds
         Assistant Director
         Division of Corporation Finance

Re:      Harbor Acquisition Corporation
         Amendment No. 6 to Registration Statement on Form S-1
         REGISTRATION STATEMENT NO. 333-126300
         -----------------------------------------------------



Dear Mr. Reynolds:

Harbor Acquisition Corporation (the "Company") has filed with the Commission an
Amendment No. 6 to the above-referenced Registration Statement (the
"Registration Statement"). For your convenience, we are providing you with three
paper copies of Amendment No. 6 marked to show the changes made from Amendment
No. 5 to the Registration Statement, which was filed with the Commission on
December 9, 2005. Following the filing of Amendment No. 5, the Commission
informed the Company that it had no further comments to the Registration
Statement.

We understand that the Commission may review the changes made in Amendment No.
6. For your convenience, I would like to identify the changes made, which are as
follows.

     1. The Company has included financial information as of and through
December 31, 2005.



Securities and Exchange Commission
March 24, 2006
Page 2

     2. John Carson, who has been a director of the Company, will serve as
Chairman of the Board of Directors. Robert J. Hanks, who was the Chairman, will
remain as Chief Executive Officer and a member of the Board of Directors.

     3. Subject to registration, the Company will complete a placement of
2,000,000 warrants at $0.65 per warrant to its initial stockholders, each of
whom is an accredited investor. The $1.3 million proceeds from the private
placement will be held in the trust account and the initial stockholders will
waive any claim to such proceeds in the event of a liquidation of the Company.
As a result, these proceeds will be available for payment to public stockholders
if the Company liquidates or to stockholders who elect to convert their shares
to cash on consummation of a business combination. The warrants and shares of
common stock underlying the warrants will be registered in the Registration
Statement to avoid any integration issues that may otherwise arise. The
purchasers will agree not to transfer the warrants until the Company consummates
a business combination.

     4. The underwriters have agreed to deposit their non-accountable expense
allowance of $1,350,000 into the trust account until the Company completes a
business combination. This amount will be paid on a pro rata basis to
stockholders who elect to convert their shares to cash on consummation of a
business combination, or forfeited to the public stockholders in the event the
Company does not complete a business combination within the time frame specified
in the prospectus.

     5. One of the Company's initial stockholders will loan the Company
$150,000, which amount will also be deposited in the trust account and repaid
from interest generated from the principal in the trust account.

     6. The working capital requirements of the Company will be funded from
interest generated from the trust account, rather than directly from the net
proceeds from the offering. As a result of this change and those described in
items 3, 4 and 5 of this letter, the principal of the trust account recoverable
by the public stockholders in the event the Company liquidates or by
stockholders electing to convert their shares to cash will increase to 96.3% of
the public offering price of the units.

     7. The Company has added a third underwriter.

     8. The Company will issue a unit purchase option to Ferris, Baker Watts,
Incorporated. (This unit purchase option and the underlying securities were
included in the Company's original filing and the registration fees have been
paid. The Company had removed the option in a subsequent amendment). The Company
has included disclosure regarding the valuation of the unit purchase option on
pages 55 and F-8 of Amendment No. 6.



Securities and Exchange Commission
March 24, 2006
Page 3

     9. Mr. Hanks and Mr. Dullum, as well as Grand Cru Management, LLC, which
they own and control, have transferred shares of common stock of the Company in
private transactions to Mr. Carson. All shares held by the initial stockholders
will be held in escrow.

     10. One of the Company's initial stockholders recently died in a tragic
plane accident. The shares held by his estate were transferred to an LLC owned
by his brother, who is one of the Company's special advisors.

     Pending confirmation that the Commission has completed its review of
Amendment No. 6, the Company anticipates requesting acceleration on or about
April 4, 2006. If you have any questions concerning the material provided
herein, please do not hesitate to call William F. Griffin, Jr., at this office,
or the undersigned.

Very truly yours,


Andrew D. Myers

cc:  Mr. Michael Carney, SEC Branch Chief, Mail Stop 3561
     Mr. Duc Dang, SEC
     Mr. Robert J. Hanks
     Mr. David A. Dullum
     Elizabeth Hughes, Esquire
     William F. Griffin, Jr.