Narrative

City of Glendale — Regular Meeting (2024-08-13)

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Three Rocks Mining 
Minor General Plan Amendment and Rezone 
Located along the Agua Fria River between Bethany Home Rd and Glendale Ave 
 
 
GPA24-01 and  ZON24-01 
 
Fist Submittal: 
February 8, 2024 
 
Second Submittal: 
May 15, 2024 
 
 
Submitted by 
Gilbert Blilie PLLC 
701 North 44th Street 
Phoenix, Arizona 85008 
(480) 429-3000 
 
 
 
City of Glendale Received May 17, 2024

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Purpose of Request 
Gilbert Blilie PLLC, on behalf of Three Rocks LLC, is requesting a Minor General Plan Amendment 
from Parks and Open Space (POS)/ Low Density Residential: 1 - 2.5 du/ac (LDR 2.5) to Heavy 
Industrial (HI) and a Rezone Request from A-1 to M-2 with a Special Use Overlay for the operation of 
a sand and gravel mine across an approximately 48-acre property located along the Agua Fria River 
between Bethany Home Rd and Glendale Ave as legally described in Exhibit A (referred to herein as 
the “Property”). The City of Glendale awarded M R Tanner Mining, Inc (Three Rocks LLC) a Real 
Property Purchase and Sale Agreement (see Appendix I) during the City’s regular City Council hearing 
on November 28, 2023 the right to purchase the Property, which consists of portions of APNs 
501-55-003B, 501-55-002A, and 501-55-012C. These parcels and the portions thereof will be 
combined by the City of Glendale upon the final purchase of the Property. 
 
Site Context 
The Property is situated within the Agua Fria floodplain approximately one-quarter mile south of 
Glendale Ave, one-half mile east of El Mirage Rd, and one-half mile west of the Glendale Municipal 
Airport. The Agua Fria corridor is an important source of high quality construction materials and a 
vast majority of this area currently consists of mining and extraction operations roughly ranging from 
Olive Ave to Indian School Rd. The City of Glendale owns and operates an aquifer recharge facility 
immediately northeast of the Property. The planned use of the Property will not affect the facility. 
Three Rocks LLC owns and operates the sand and gravel mine immediately west of the site 
stretching to El Mirage Rd and which this Property will be an extension of. 
 
 
Land Use 
Zoning 
Existing Conditions 
North 
HI and PF 
A-1 
The City of Glendale owns the majority of the land 
north of the Property up to Glendale Rd, which includes 
an aquifer recharge facility and an abandoned mining 
pit. Maricopa County also owns roughly 18 acres within 
the Agua Fria River floodplain and along Glendale Ave. 
M R Tanner, Inc has agreed to backfill, compact, and 
grade a portion of this area as part of the Real Property 
Purchase and Sale Agreement (see Exhibit B). North of 
Glendale Rd includes additional mining and extraction 
operations within the Agua Fria corridor, towing and 
junkyard uses, as well as the Glendale Regional Public 
Safety Training Center and Landfill. 
East 
POS, HI, and 
BP 
RU-43 (Maricopa 
County) 
Additional mining operations are located east of the 
Property in unincorporated Maricopa County and in the 
City of Glendale up to the Glendale Municipal Airport 
South 
Parks/Open 
Space (City 
of Phoenix) 
RU-43 (Maricopa 
County) 
The land south of the Property consists entirely of 
mining operations within the Agua Fria corridor. 
West 
LDR 2.5 
RU-43 (Maricopa 
County) 
The land west of the Property is owned by Three Rocks 
LLC for sand and gravel mining operations up to El 
Mirage Rd and as far north as Glendale Ave.

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Project Overview 
The sand and gravel mining operations planned for the Property will excavate unconsolidated sand 
and gravel resources for processing at the existing crushing, washing, and sorting plant on the 
adjacent Three Rocks LLC property. Excavation will occur on approximately 86 acres which includes 
the Property and a contiguous property also owned by Three Rocks LLC, APN501-55-011C, as shown 
on the site plan submitted with this application. The excavated pit is expected to be approximately 
65 feet deep. However, the actual depth of the mining operations is not known until soil samples can 
be taken to understand the depth of the economical sand and gravel materials that will be extracted. 
 
Operations on the Property will include material excavation using traditional tracked or wheeled 
excavators, then transport to the adjacent Three Rocks LLC site to the west using off-road trucks for 
processing. There will be no blasting or use of explosives to mine or process materials, nor will there 
be any infrastructure or utilities constructed or used on the Property. Finished products will be 
transported from the adjacent Three Rocks LLC property in the County to their destination as 
currently occurring on the Three Rocks LLC operation. 
 
Fueling and light maintenance (such as oiling, greasing, and filter replacements) may be performed 
on the mobile equipment on the Property on an as needed basis, but there will be no fuel storage or 
major maintenance activities/facilities constructed or conducted on the Property. Offices, parking, 
restrooms, material and equipment storage, and waste receptacles are all located on the adjacent 
Three Rocks LLC facility located in unincorporated Maricopa County. So, there will be no buildings or 
other structures, parking, storage, or disposal of solid or other regulated wastes on the subject 
Property.  
 
Operating hours are generally limited to daylight hours during the normal business week 
(approximately 7:00 am to 5:00 pm Monday through Friday). However, operations may be 
temporarily extended to meet short term project demands or emergency projects on an as needed 
basis. For this reason, there will be no structured lighting installed on the Property. However, the 
mobile excavating equipment will have headlights when needed during non-daylight hours. Although, 
since these headlights will be below grade operating inside the pit, there will be virtually no lighting 
impacts on surrounding properties. This Property is also not adjacent to any residential homes that 
would potentially be adversely affected by the use of headlights. 
 
Dust will be mitigated by limiting traffic speed and water applications. Operations, monitoring, 
recordkeeping, and reporting will be conducted in accordance with an approved Maricopa County air 
permit. 
 
All mine activities will be regulated by the United States Mine Safety and Health Administration 
(MSHA) under the approved Mine Site Identification used by Three Rocks LLC. No operations will 
take place when significant flows occur in the Aqua Fria River and the vertical and horizontal limits of 
excavation will be in conformance with the approved Aggregate Mined Land Reclamation Plan 
administered by the Arizona State Mine Inspector (ASMI) and the Floodplain Use Permit (or 
equivalent entitlement) issued by the City of Glendale. 
 
Once it is determined that the appropriate unconsolidated sand and gravel resources have been 
excavated from the property, the site will be reclaimed back to its purpose as a primary floodway of 
the Agua Fria River. The Reclamation Plan will be approved by the ASMI and will include a suitable 
financial assurance mechanism to guarantee that planned reclamation efforts are conducted in the 
event of default.

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Phasing 
This mining operation will be conducted in three phases. Phase one will include the construction of 
the upstream inlet structure to channel and divert the flow of water through the Agua Fria River to 
avoid water pooling in the mine pit. The second phase consist of the mining operation conducted 
across the Site at approximate 10-foot lifts. The third phase will include the installation and 
construction of the remaining erosion control structures and the preparation of the final reclamation 
surfaces. 
 
Access 
Access to the Property will be provided through the adjacent Three Rocks LLC property to the west, 
which maintains an existing controlled access point on El Mirage Rd for its current operations. 
Unpaved mine roads will enter and exit the property to move equipment and transport excavated 
materials to the adjacent processing area. These roads will be constructed to MSHA standards for 
heavy equipment and off-road trucks and are adequate for emergency vehicle access. Cross-access 
easements will be provided where needed between separate properties. 
 
Direct access to Glendale Rd is not determined to be necessary at this time, but may be revisited 
with the City of Glendale in the future if necessary. 
 
Infrastructure 
The sand and gravel mining operations on the Property do not require water and sewer infrastructure 
to be delivered to the site. Water used for dust control will be brought to the property using a 
dedicated water truck filled on the adjacent Three Rocks LLC property. No structures, utilities, waste 
receptacles, or restrooms will be constructed on the Property. 
 
Community Benefits 
The proposed amendment furthers the public health, safety and general welfare of the citizens of 
Glendale. Sand and gravel produces are a needed commodity for nearly all construction projects in 
the City of Glendale and elsewhere. Extracting these resources in closer proximity to the construction 
projects where they are utilized reduces the travel time and energy expended to deliver these 
materials to the construction site, which in turn reduce local costs of construction, minimize road 
wear and vehicle emissions.  
 
The Aqua Fria River floodplain in the area of the Property has been significantly altered by 
abandoned mining pits that were never backfilled, wildcat dumping of construction waste, and 
demolition debris. As a consequence, the river hydraulics have been significantly altered and flows 
through the property are not typical of efficient riparian systems. As reflected in the Floodplain Use 
Permit and Reclamation Plan, the planned mining will improve river hydraulics, establish more 
desirable riparian conditions and may reduce the extent of floodplain and floodway in the area. 
 
Additionally, as part of this mining operation and per the Real Property Purchase and Sale 
Agreement, M R Tanner Mining, Inc will make improvements to an offsite property approximately 850 
feet long and 400 feet wide adjacent to Glendale Rd, inclusive of the northern portion of APN 
501-55-003B and the northeastern portion of 501-99-001J. These improvements will include a 
berm along the south side of Glendale Rd, as well as backfilling, compacting, and grading of a 
portion of an abandoned aggregate pit.

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All mines in Arizona located on private lands are required to obtain an ASMI-approved mined land 
Reclamation Plan (Plan). The Plan will address means and methodologies for Three Rocks LLC to 
remove valuable aggregates from the Property and restore the Property consistent with the selected 
post mining land use, Floodplain Use Permit requirements, and safe and geotechnically stable 
conditions. The Plan will be prepared by Three Rocks LLC in consultation with the City of Glendale 
and ASMI approval of the Plan will require notification of the City and the surrounding community. 
Estimated reclamation costs, detailed in the approved Plan, will be bonded by Three Rocks LLC in 
the unlikely potential that Three Rocks LLC cannot perform the reclamation as prescribed in the 
Plan. 
 
Consistency with the General Plan 
The requested amendment to the General Plan Land Use Map will be compatible with the adjacent 
uses as virtually all of the surrounding uses are active mining operations, including those 
immediately east, west, and south. In fact, the mining operations east and north of the Property are 
designated as HI on the Land Use Map, equivalent to this request. It should also be noted that the 
Reclamation Plan that will be prepared in connection with the approved mining activities will restore 
the land as riparian open space once the mining activities are completed on the Property. This post-
mining land use will provide a significant community asset, and will be compatible with the current 
Parks and Open Space land use designation on the City’s General Plan Land Use Map today.  
 
This request is also consistent with and supported by the City’s General Plan as shown in the 
following goals and policies: 
 
Goal LU-1. Development is guided by sound growth management 
• 
Policy LU‐1.3 The City shall work with adjacent jurisdictions to promote compatible land use. 
 
This use is compatible with all adjacent uses, including those within unincorporated Maricopa 
County. There are active mining operations all along the Agua Fria river corridor between Olive Ave 
and Indian School Rd. 
 
Goal LU-6. The City strives for equal protection for residential development and aggregate mining 
operations by promoting compatible land uses in areas of close proximity to existing or planned 
aggregate and mineral mining operations. 
• 
Policy LU‐6.1 The City shall discourage new residential zoning where future residences 
would be adjacent to an existing or planned aggregate /mineral mining operation. 
• 
Policy LU‐6.2 The City should promote non‐residential development, such as business park 
and industrial uses, adjacent to existing, future or proposed aggregate / mineral mining 
operations. 
 
Since the Property is virtually completely surrounded by other active mining operations along and 
adjacent to the Agua Fria river corridor, residential uses are simply not appropriate in this location. 
However, the proposed sand and gravel operation will be the most appropriate and compatible use 
for the subject Property given its context and consistent with this General Plan goal.

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Rezone and Special Use Overlay 
Although there will be no structures placed on the Property, the use of this Property will be in 
compliance with the M-2 development standards. A comparison representing the compliance with 
these development standards is provided below: 
 
Development Standards 
M-2 
Proposal 
Min. Net Lot Area 
6,000 SF 
47.85 acres 
Max. Lot Area 
N/A 
N/A 
Min. Setback 
 
 
Front 
25’ 
N/A 
Rear 
60’ 
N/A 
Side 
60’ 
60’ 
Street Side 
25’ 
N/A 
Max. Structure Height 
30’ 
N/A 
Max. F.A.R. 
0.30 
N/A 
 
A Special Use District Overlay is also required for the operation of this sand and gravel mine to 
excavate, crush, and process materials per Unified Development Code section 35.2.902C.1.(f). The 
use of this Property will abide by all requirements and standards of the Special Use District Overlay 
and other provisions in the City of Glendale Unified Development Code. 
 
Conclusion 
The subject Property, which is currently virtually entirely surrounded by sand and gravel mines, was 
put for bid by the City of Glendale City Council and awarded to M R Tanner, Inc for mining purposes. 
The approval of this request will simply fulfill M R Tanner’s obligation as part of the purchase 
agreement to entitle the Property for a sand and gravel mining use, which will thus allow the 
expansion and continuation of an existing mining operation by the adjacent Three Rocks LLC mining 
operation. The only use of the Property will be sand and gravel mining. As such, there will be no 
structures or other infrastructure constructed on site. All sand and gravel resources extracted from 
the subject Property will be hauled to the adjacent property to the west also owned by Three Rocks 
LLC for processing and distribution.  
 
There are no residences of sensitive businesses within the vicinity of the Property that will be 
adversely affected by this use. All mine activities will be regulated by the United States MSHA under 
the approved Mine Site Identification used by Three Rocks LLC.  
 
Importantly, M R Tanner and its subsidiary Three Rocks LLC are committed to reclaiming and 
backfilling the mine after the appropriate unconsolidated sand and gravel resources have been 
excavated from the property, which will return the Property back to its purpose as a primary floodway 
of the Agua Fria River with a financial assurance mechanism to provide assurance that these 
commitments are met.