The knowledge has to belong to the employer. Special knowledge of the company's own product, technique or equipment and how it is applied in international markets, or an advanced level of knowledge of the company's processes and procedures, is the standard. Broad competence in marine construction, however uncommon, does not meet it.
Ask where the knowledge was acquired
The most useful diagnostic is not how good somebody is but where the knowledge came from. If it could have been obtained at any competent employer in the trade, or from a manufacturer's public training course, it is general knowledge and belongs to the industry. If it was built inside the petitioning organization, from its own designs, its own failures, its own testing regime and its own customer base, the claim has somewhere to stand.
Erez's position is promising because the anchoring specification is the company's intellectual property and the load-testing procedure exists in no published standard. It becomes weaker if the petition drifts into praising his work ethic, his years of experience or the shortage of installers willing to work on ice. Those are recruiting arguments, not classification arguments.
The petition should also be honest about which branch it relies on, because proprietary product knowledge and advanced process knowledge are proved with different material and a file that hedges between them proves neither.