Freight Information Gathering System

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1 Freight Information Gathering System OCTOBER - DECEMBER QUARTER OF 2011 ISSN JUNE 2012 QUARTERLY CONTAINER INFORMATION REPORT

2 Contents 1. Executive Summary Limitations FIGS cargo movements explanatory note Glossary Summary tables Map 1: Container loads and discharges (full and empty) Map 2: Full container loads and discharges Map 3: Empty container loads and discharges Container movements: imports, exports and transhipment loads Exports and imports 20 foot and 40 foot container balance Imports and exports container numbers and TEU Classification of export and import cargos Containerised export classification Land transportation method road or rail Coastal movements of containers on domestic ships Hazardous containerised cargo Information completeness Appendix A: Coastal movements (net tonnes) Appendix B: Coastal TEU movements (container movements)...29 Page 2 of 33

3 1. Executive Summary This report is the second quarterly container information report from the Freight Information Gathering System (FIGS). The information in this report is from the quarter of 1 October 31 December 2011 for the following eight ports: Auckland Tauranga (including MetroPort) Napier (New Plymouth) (Wellington) (Dunedin) (Bluff) The information available to government on the movement of freight into, out of, and around New Zealand has been limited. The purpose of FIGS is to provide a detailed understanding of this traffic, including volumes, export/import imbalances and the mode of inland transportation used to carry cargo to and from ports. FIGS information will be used to inform policy, planning and infrastructure decisions, and will extend the information available to be used in such decisions by providing robust, reliable and consistent information. The information in this report is limited to the eight container ports listed above. Information from Lyttelton (Christchurch) and from PrimePort Timaru is not included in this report as it was not live in FIGS for the entire quarter. The next report (January March 2012) will include information from all ten container ports. This report covers container freight only, and does not extend to bulk freight information. Including bulk freight information is the next stage in the project, and plans to collect this information are currently being investigated. Key terms are defined in the glossary on page 7. Key Findings The key findings for the eight ports in the October December 2011 quarter are: 49.7 percent of all containers imported to these eight ports were imported through Auckland percent of all containers exported from these eight ports were exported through Tauranga. The three most exported commodities (dairy products, wood products and paper products) made up the majority of the containers exported (59.1 percent), accounting for 29.1 percent, 15.8 percent and 14.2 percent respectively. 17 percent of coastal container traffic was moved on domestic ships percent of exports are known to have been moved to the ports by road, 22.6 percent by rail and the remaining 11.5 percent could have been moved by either mode percent of all containers are known to have left the ports by road, 15.7 percent by rail, and the remaining 12.9 percent have an unknown land mode. Page 3 of 33

4 Full and empty exports and imports Full Empty Dry 20 foot container exported 77 percent 23 percent 51,308 Refrigerated 20 foot container exported 98 percent 2 percent 15,300 Dry 20 foot container imported 93 percent 7 percent 53,578 Refrigerated 20 foot container imported 24 percent 76 percent 13,749 Dry 40 foot container exported 89 percent 11 percent 46,764 Refrigerated 40 foot container exported 93 percent 7 percent 7923 Dry 40 foot container imported 63 percent 37 percent 49,138 Refrigerated 40 foot container imported 64 percent 36 percent Limitations The information in this report is limited to eight ports participating in FIGS for the full October December 2011 quarter and includes information on containers only. No information on bulk freight is included in this report. We estimate that the eight ports covered in this report were responsible for 86 percent of container movements in 2009/ Rockpoint New Zealand Port Sector 2010 report Page 4 of 33

5 3. FIGS cargo movements explanatory note The characterisation of cargo movements in FIGS is designed to split shipping movements into international and coastal. For instance the term export is confined to international movements in FIGS, and transhipment is confined to coastal movements. Table 1: Definition of International Movements International movements Import Export Re-export The container arrives at a New Zealand port by ship, directly from overseas. Example: San Francisco to a New Zealand port. The container is loaded onto a ship in a New Zealand port and is shipped overseas directly. Example: A New Zealand port to China. The container arrives in New Zealand from overseas full, is loaded onto a different ship without leaving the port and without the cargo changing, and is then exported. Example: United States of America to a New Zealand Port then on to Fiji. Table 2: Definition of Coastal Movements Coastal movements Export transhipment Import transhipment Domestic The container is loaded at a New Zealand port, is shipped to a second New Zealand port, discharged and is then loaded for export without leaving the second port, and without the cargo changing. Example: New Zealand Port 1 to New Zealand Port 2 to Singapore In the FIGS, the New Zealand Port 1 to Port 2 coastal movement is an export transhipment. The New Zealand Port 2 to Singapore international movement is an export. The cargo arrives from overseas at a New Zealand port, is discharged and then loaded onto another ship without leaving the port or the cargo changing, and is then shipped to a second New Zealand port, is discharged and gated out. Example: Shanghai to New Zealand Port 1 then to New Zealand Port 2. In the FIGS, the Shanghai to New Zealand Port 1 international movement is an import. The New Zealand Port 1 to New Zealand Port 2 coastal movement is an import transhipment. Movements of containers from one New Zealand port to another New Zealand port, which are not import or export transhipments. Example: Gate in New Zealand Port 1 for loading, then ship to New Zealand Port 2 for discharge and gate out Export transhipments of full containers are identified in FIGS using the booking reference, and export transhipments of empty containers are identified by following the sequence of container movements. This approach is being used as although the container load and discharge messages can include a transhipment value, not all ports code it. Page 5 of 33

6 Figure 1: International and Coastal movement diagrams FIGS International movements are shown in blue FIGS Coastal movements are shown in orange Overseas Import C. Import and import transhipment NZ Port A Discharge Load onto a different vessel Import transhipment NZ Port B Discharge Gate out Overseas Import B. Export and domestic NZ Port A Discharge Gate out Gate in Load Domestic NZ Port B Discharge Gate out NZ Port A Gate in Load Export transhipment C. Export transhipment and export NZ Port B Discharge Load onto a different vessel Export Overseas Page 6 of 33

7 4. Glossary Coastal Movements Discharge Domestic ship FIGS Gate in Gate out Hazardous loads International ship Load Net tonnes Reefer See page five Unloading a container from a ship A ship registered in New Zealand. All New Zealand registered ships must comply with New Zealand labour and safety laws, as well as maritime laws. For FIGS purposes, domestic ships are; the Santa Regina, the Spirit of Endurance, the Spirit of Resolution, and the Monte Stello Freight Information Gathering System The entry of a container to a port by road or rail. One exception is after a container is packed within a port, a gate in message can be sent to reveal that the container is available for loading, even though it has not physically entered the port The exit of a container from a port by road or rail The ports record whether or not containerised cargos are hazardous All ships not registered in New Zealand. They must comply with maritime law, but not New Zealand domestic law Loading a container onto a ship Net container weight is the weight of the cargo. It is the gross weight recorded in the port message, less the typical weight for that type of container (20 foot dry, 20 foot reefer, 40 foot dry, 40 foot reefer) A reefer is a container that can be refrigerated TEU Twenty foot equivalent unit. A 20 foot container is one TEU, and a 40 foot container is two TEU. The report typically counts containers when reporting on the volume of loads and discharges (it is more effort to discharge two 20 ft containers than one 40 foot container, even though they each constitute two TEU). The report typically counts TEU when reporting on cargo movements Page 7 of 33

8 5. Summary tables The following tables provide a summary of total container movements from all eight ports. The information is broken down by type of movement, and allows for size and type comparisons between the different ports. Import tranship ments Domestic Coastal unknown Auckland 62,838 31, , ,236 Tauranga 35,801 59, ,954 Napier , , , , , , ,295 11,908 20, , ,163 Table 3A expands on the total column in Table 3, showing how it breaks down. Table 3A: Container loads and discharges container % of total loads and discharges Full loads and discharges % of full Empty loads and discharges % of empty Auckland 130,236 39% 103,579 42% 26,657 29% Tauranga 115,954 34% 84,742 35% 31,212 34% Napier 24,507 7% 14,976 6% 9,531 11% % 3,193 1% 1,658 2% 17,151 5% 12,852 5% 4,299 5% 11,779 4% 6,852 3% 4,927 5% 27,026 8% 16,344 7% 10,682 12% % 3,033 1% 1,626 2% 336, % 245, % 90, % Table 3: Summary totals: containers loaded and discharged Export Imports Exports Reexport tranship ments Table 4: Summary totals: Net weight of full containers loaded and discharged (in tonnes) Imports Exports Export Import Reexports unknown Coastal tranship tranship Domestic ments ments Auckland 745, , ,845 51,297 37, , ,552,969 Tauranga 306, , ,271 71, ,705 15,421 40, ,575,833 Napier 306,306, 46, , , , , ,069 46,541 18, , ,023 23,452-11, , ,271 18,922 81,296 23,452 76, ,295 12, ,900 13,635 32,886-66, , ,565 24, , , , ,082 17,833 41, ,827 1,255,21 4 1,990, , ,302 76, ,948 19,124 4,202,196 Page 8 of 33

9 Table 4A: Average full container net weight Net tonnes loaded and discharged Net tonnes/container Net tonnes/teu Auckland 1,552, Tauranga 1,575, Napier 284, , , , , , ,202, TABLE 5: Twenty foot Equivalent Units (TEU) loads and discharges container % of total Full loads % of full Empty loads and % of empty discharges Auckland 187,480 38% 149,558 42% 37,922 28% Tauranga 172,129 35% 123,687 35% 48,442 36% Napier 35,656 7% 21,368 6% 14,288 11% % 3,895 1% 2,153 2% 23,387 5% 17,610 5% 5,777 4% 17,246 4% 9,979 3% 7,267 5% 40,106 8% 23,776 7% 16,330 12% % 4,378 1% 2,959 2% 489, % 354, % 135, % Page 9 of 33

10 6. Map 1: Container loads and discharges (full and empty) Note: Please refer to table 3 for the figures for this map. Page 10 of 33

11 7. Map 2: Full container loads and discharges Note: Please refer to table 3 for the figures for this map. Page 11 of 33

12 8. Map 3: Empty container loads and discharges Note: Please refer to table 3 for the figures for this map. Page 12 of 33

13 9. Container movements: imports, exports and transhipment loads Figure 2 shows the split of imports, exports and transhipment movements in terms of TEUs, by port. The key point illustrated by Figure 2 is the type of container movement that is most prevalent at each port. For example, in this quarter, imports were the most common type of container movement at the Auckland, accounting for over 60 percent of the total movements. Note: These reports show container movements. Imports are reported to FIGS as container discharges, exports as container loads, and coastal transhipments as a load in one port and a discharge in another. To prevent double counting of transhipments, only loads of coastal transhipments are included in this analysis. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Figure 2 : Import, export and transhipment movements (TEU) Auckland Tauranga Napier Port 8 ports Taranaki Imports Exports Export transhipment load Import transhipment load Table 6 shows container movements related to overseas trade. It shows the number of TEUs and the number of containers exported, imported, and loaded for transhipment. Table 6: Container numbers and TEUs for overseas trade exported, imported and loaded for transhipment Port Export, import and transhipment TEU Export, import and transhipment 20ft containers Export, import and transhipment 40ft containers Export, import and transhipment total containers Auckland 139,069 57,105 40,982 98,087 Tauranga 143,543 48,791 47,376 96,167 Napier 28,444 10, , , ,033 11, ,642 10, , , , , ,843 Page 13 of 33

14 10. Exports and imports 20 foot and 40 foot container balance Figure 3 illustrates the net tonnes exported by container type. 40 foot dry containers carried the largest proportion of net tonnes exported (47 percent) and over a third (34 percent) were exported in 20 foot dry containers. 20 foot and 40 foot reefer containers accounted for 11 percent and 8 percent of exported containers respectively. Figure 3 : Net tonnes exported, by container type 8% 34% 47% 20ft dry 20ft reefer 40ft dry 40ft reefer 11% Figure 4 illustrates the net tonnes imported by container type. The majority (57 percent) of net tonnes imported are imported in 20 foot dry containers and 33 percent are imported in 40 foot dry containers. 20 foot and 40 foot reefer containers accounted for 2 percent and 8 percent of imported containers respectively. 2 Figure 4 : Net tonnes imported, by container type 8% 33% 57% 20ft dry 20ft reefer 40ft dry 40ft reefer 2% 2 Please note that this includes all reefer containers, although some may not have been operating in refrigerator mode. Page 14 of 33

15 TEU 11. Imports and exports container numbers and TEU Full and empty TEU During the quarter, 185,387 TEU containers were imported (full and empty), and the majority (68.9 percent) were full. A total of 175,982 TEU containers were exported (full and empty), and again the majority (86.3 percent) were full. During the period of 1 October 31 December 2011 there was a difference of 24,104 TEU between the full TEU of imported goods (127,773) and the full TEU of exported goods (151,877) for the ports from which the information was gathered. Figure 5 : Import and export TEU 160, , , ,000 80,000 60,000 40,000 20,000 - Full TEU Empty TEU Import TEU Export TEU Exports and imports of 20 foot/40 foot containers Twenty foot containers: 54,407 twenty foot containers were exported full (40.6 percent), 52,851 were imported full (39.5 percent), 12,201 were exported empty (9.1 percent) and 14,476 were imported empty (10.8 percent). Forty foot containers: 48,735 forty foot containers were exported full (42.9 percent), 37,461 were imported full (32.9 percent), 5952 were exported empty (5.2 percent) and 21,569 were imported empty (19 percent). Page 15 of 33

16 Containers Figure 6 : Containers exported full versus exported empty ft 40ft Exported full Exported empty TABLE 7: Container numbers import and export (20 foot and 40 foot) 20ft dry/ full 20ft dry/ empty 20ft reefer/ full 20ft reefer/ empty 40ft dry/ full 40ft dry/ empty 40ft reefer/ full 40ft reefer empty Import container 49, ,502 31,107 18, Export container 39,430 11,878 14, , Import TEU Full TEU Empty TEU 127,773 57,614 Export TEU 151,877 24,105 Reefer means the container is a reefer type it may not necessarily be operating in refrigerator mode. Figures 6A and 6B show the amounts of containers exported and imported full and empty. It is clear that more dry containers are exported empty than reefer containers. It is also clear that 20 foot reefer and 40 foot dry are more likely to be imported empty than 20 foot dry or 40 foot reefer. Page 16 of 33

17 Containers Containers Figure 6A : Containers exported ft dry 20ft reefer 40ft dry 40ft reefer Exported full Exported empty Figure 6B : Containers imported ft dry 20ft reefer 40ft dry 40ft reefer Imported full Imported empty 12. Classification of export and import cargos Only a limited percentage of import containers have been classified by commodity group 3. This is because much of the import cargo is described as General cargo or Freight all kinds. However, there is more information available of the export containers. Around 93 percent of export containers are classified in the eight ports as shown in Figure 7, with percent of export containers being classified at some ports. 3 A list of the harmonised freight commodity codes is available at: Page 17 of 33

18 Figure 7 : Cargo that could be classified, by port 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Imports Exports Page 18 of 33

19 13. Containerised export classification Figure 8 : Containerised export commodity breakdown (TEU) Animal : dairy Wood products Paper products Not classifiable Animal : meat Foodstuffs Metals Vegetable products Food unclassified Chemicals Animal : fish Machinery/electrical Plastics/rubbers Miscellaneous Textiles, clothes and footwear Animal : other Hides, skins, leather and furs Mineral products Stone and glass Transportation TABLE 8: Export breakdown by commodity 4 group Commodity Group Export Breakdown % Animal : dairy 29.1 Wood products 15.8 Paper products 14.2 Not classifiable 6.9 Animal : meat 6.6 Foodstuffs 5.1 Metals 4.2 Vegetable products 3.9 Food unclassified 3.5 Chemicals 2.2 Animal : fish 2.2 Machinery/electrical 1.6 Plastics/rubbers 0.9 Miscellaneous 0.8 Textiles, clothes and footwear 0.8 Animal : other 0.6 Hides, skins, leather and furs 0.6 Mineral products 0.5 Stone and glass 0.3 Transportation Commodities have been classified against the highest level of the harmonised cargo classification. The only exception to this is footwear and hats, which have been combined with textiles and clothing. Page 19 of 33

20 TABLE 9: Container types used for exports and imports 20ft dry 20ft reefer Exports 40ft dry 40ft reefer Imports Reefer means the container is a reefer type it may not necessarily be operating in refrigerator mode. 20ft dry 20ft reefer 40ft dry 40ft reefer Full container, unknown cargo , , Animal : meat Animal : dairy 10, , Animal : fish Animal : other Foodstuffs Chemicals Hides, skins, leather and furs Mineral products Machinery/electrical Miscellaneous Metals Plastics/rubbers Stone and glass Transportation Paper products Vegetable products Wood products , Textiles, clothes and footwear Food unclassified full containers 39,430 14,977 41, , , empty containers 11, ,502 18, containers 51,308 15,300 46, ,578 13,749 49, % full Page 20 of 33

21 TEU 14. Land transportation method road or rail Figure 9 : Land mode to and from ports (TEU) Road Rail Unknown In Out During the October December 2011 quarter, 217,678 TEU were transported to the eight ports by land 5. The land mode by which it arrived was known for 88.5 percent of TEUs. During this period, 65.9 percent were known to have come by road and 22.6 percent were known to have come by rail. The remaining 11.5 percent could have come into the port using either road or rail. 6 During the October December 2011 quarter, 215,031 TEU exited the eight ports. The land mode by which it exited was known for 87.1 percent of TEUs. During this period, 71.4 percent of TEUs were known to have exited by road and 15.7 percent by rail. The remaining 12.9 percent could have come out of the port using either road or rail. 5 MetroPort is a dry port located in Auckland. Cargo is transmitted via train between Tauranga and MetroPort for distribution and transportation. These reports do not include MetroPort gate-in or gateout information so as to avoid double counting movements between Tauranga and MetroPort. 6 Also note that some ports have an empty container depot which does not record container arrivals in the port data system. Any subsequent move to the port, from the empty depot, will typically appear in the port system as arriving by road. The container may have arrived at the empty container depot by rail, but that movement is not recorded in these circumstances. Page 21 of 33

22 TEU TEU Figure 10 : Land mode of entry to ports (TEU) International import/export Coastal Gate in road Gate in rail Gate in unknown Figure 11 : Land mode of exit from ports (TEU) International import/export Coastal Gate out road Gate out rail Gate out unknown The proportion of unknown information varies between different types of container movements. The percentage known is higher for international exports and imports than coastal shipping, but the amount known exceeds 86 percent across all four categories- costal gate in, coastal gate out, international gate in and international gate out. Import transhipments have the greatest proportion (95.9 percent) of land mode known, while the land mode for domestic cargo coming out of ports has the lowest proportion, with 83.1 percent known. Page 22 of 33

23 TEU 15. Coastal movements of containers on domestic ships Containers are carried on both international and domestic ships. The vessels that were regarded as domestic are Santa Regina, Spirit of Endurance, Spirit of Resolution and Monte Stello. Figure 12 demonstrates the share of coastal movements on domestic ships. The key point it illustrates is that 17 percent of containerised coastal movements were carried on domestic ships during this quarter. 30% Figure 12 : Share of containerised coastal movements on domestic ships (TEU) 25% 20% 15% 10% 5% 0% Export transhipment load Import Domestic load transhipment load Unknown movement to North Island Unknown movement to South Island Figure 13 shows the breakdown of coastal movements by load type, and illustrates that the largest amount of loads are domestic loads, on international ships Figure 13 : Coastal movements (TEU) Export transhipment load Import transhipment load Domestic load Unknown movement to North Island Unknown movement to South Island International ship full container International ship empty container NZ ship full container NZ ship empty container TABLE 10 Domestic and international containers full and empty TEU % of Domestic ship - full container % domestic Domestic ship - empty container % 17% International ship - full container 24,487 43% international International ship - empty container 23,209 40% 83% Page 23 of 33

24 16. Hazardous containerised cargo The ports defined whether cargo is hazardous. Examples of the types of cargo defined as hazardous include chemicals, poisons and gas cylinders. Figure 14: Percentage of hazardous cargo by shipment type 7% 6% 5% % hazardous TEU % hazardous net tonnes 4% 3% 2% 1% 0% Export Import Export Import Re-export Domestic Unknown Unknown transhipment transhipment North Island South Island Figure 15 : Hazardous TEU by shipment type Export Import Export transhipment Import transhipment Re-export Domestic Unknown North Island Unknown South Island Figure 14 illustrates hazardous TEU and splits out the proportion of each container type. The majority (85.1 percent) of TEU that are hazardous are imports. Exports account for 10.4 percent and the remaining 4.5 percent are export and import transhipments, re-exports, domestic movements and unknown data types. Shipping Figure 15 breaks down the percentage of hazardous cargo for each container movement type in TEU and net tonnes. Page 24 of 33

25 17. Information completeness There has been interest in knowing what inland origin/destination the cargo had come from or was going to (as shown by the orange bars in Figure 16, but this information is often not available. Complete information should be available for Auckland in the next quarterly report. In this quarter, there were six ports (MetroPort, Tauranga,,, and ) which had 100 percent of the transportation method (either road or rail) known. 100% Figure 16 : Data completeness by port Rail/road and inland origin/destination 80% 60% 40% 20% 0% Rail/road known Inland origin/destination known Known inland origin/destination same as the port TABLE 11: Loads without final port stated Port Known Missing % not known Auckland - 57,728 57, Tauranga 64,392-64,392 0 Napier 12,074-12, , , ,265 61, , Having accurate knowledge of the final port destination allows for a thorough freight picture to be built, and enables tracking of complete freight routes. Only a limited percentage of import containers have been classified by commodity group. This is due to many of the imports being labelled as simply general cargo or freight all kinds. Future reports will aim to reduce the amount of unclassified commodity information. Page 25 of 33

26 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort 18. Appendix A: Coastal movements (net tonnes) These tables show freight movements by weight. Each table is a breakdown of freight movements between domestic ports. See table 2 for a definition of transhipment. coastal loads: net tonnes Destination Auckland ,807 10, , , ,143 Tauranga 13, , ,590 Napier ,329 42,792 Port Taranaki 11,574 11, , ,665 Port Nelson 17, , ,717 11,426 14, , ,852 Domestic loads: net tonnes Destination Auckland , , ,203 Tauranga , ,028 Napier , , ,497 Page 26 of 33

27 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Import transhipment loads net tonnes Destination Auckland , , ,499 Tauranga , ,682 Napier ,746 Export transhipment loads net tonnes Destination Auckland Tauranga Napier ,803 39,019 11,519 11, , ,836 16, ,323 66, , , ,790 Page 27 of 33

28 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Unknown loads: net tonnes Destination Auckland Tauranga Napier Page 28 of 33

29 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru 19. Appendix B: Coastal TEU movements (container movements) These tables show freight movements by twenty-foot equivalent units. Each table is a breakdown of freight movements between domestic ports. coastal TEU loads (Full and empty containers, all domestic, transhipment and unknown coastal movements) Destination Auckland , ,889 Tauranga Napier ,468 coastal empty TEU loads Destination Auckland ,992 Tauranga Napier ,608 Page 29 of 33

30 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Domestic empty + full TEU loads Destination Auckland , ,927 Tauranga Napier ,370 Domestic empty TEU loads Destination Auckland ,750 Tauranga Napier ,298 Page 30 of 33

31 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Import transhipment empty + full TEU loads Destination Auckland Tauranga Napier Import transhipment empty TEU loads Destination Auckland Tauranga Napier Page 31 of 33

32 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Export transhipment empty + full TEU loads Destination Auckland Tauranga Napier ,715 Export transhipment empty TEU loads Destination Auckland Tauranga - Napier Page 32 of 33

33 Origin Auckland Onehunga Tauranga Napier Lyttelton PrimePort Timaru Unknown loads Destination Auckland Tauranga Napier Page 33 of 33

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