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Three Rocks Mining
Phase 2
Annexation, Minor General Plan Amendment, and Rezone
Located along the Agua Fria River between Bethany Home Rd (alignment) and
Maryland Ave (alignment) approximately 2,500 feet east of El Mirage Rd
AN-268, GPA25-02, ZON25-04
Submitted:
June 2, 2025
Submitted by
Gilbert Blilie PLLC
701 North 44th St
Phoenix, Arizona 85008
(480) 429-3000
Received June 2, 2025
2
Purpose of Request
Gilbert Blilie PLLC, on behalf of MR Tanner Mining, Inc (parent company of the property owner of
record Three Rocks LLC), is requesting the annexation of approximately 39 acres of land located
southeast of the southeast corner of El Mirage Rd and Glendale Ave, APN 501-55-011C, as legally
described in Exhibit A (referred to herein as the “Property”). Concomitantly, we are 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 to M-2 with a Special Use Overlay for a sand
and gravel mining operation across the 39-acre property being annexed.
The approval of the annexation, general plan amendment, and rezone requests will allow the
expansion of the adjacent Three Rocks LLC mining operation immediately to the west, as well as
provide for a larger and more efficient mining operation for the Three Rocks LLC property
immediately to the east that was recently purchased from the City of Glendale and entitled for sand
and gravel mining operations in 2024.
The approval of this mining operation constitutes Phase 2 of a multi-phase effort to mine the high-
quality aggregate resources within the Agua Fria River, then backfill the mined areas with inert fill
once the aggregates are extracted for future redevelopment in the City of Glendale. Phase 1 was
completed with the acquisition of the adjacent 48 acres from the City of Glendale and approved
General Plan Amendment and Rezoning. Subsequent phases will include the annexation and
development of the remaining Three Rocks LLC mining operation in the County as the 308-acre
mining pit is backfilled.
Site Context
The 39-acre Property is situated within the Agua Fria floodway and floodplain approximately 2,550
feet east of El Mirage Rd and 2,550 feet south of Glendale Ave, as well as approximately 3,500 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. This is inclusive of the Three Rocks
LLC current mining operation in Maricopa County immediately west of the site to El Mirage Rd,
consisting of over 300 acres, as well as the 48 acres recently purchased from the City of Glendale in
2024 for mining purposes. The general plan amendment and rezone applications for the property
purchased from the City of Glendale for the future mining operations were approved by City Council
on August 13, 2024 (GPA24-01 and ZON24-01). See Exhibit B. Site Context.
Land Use
Zoning
Existing Conditions
North
HI
M-2
MR Tanner Mining purchased the adjacent property to
the north from the City of Glendale in 2024 for mining
purposes. North of Glendale Rd includes additional
mining and extraction operations within the Agua Fria
corridor, as well as the Glendale Regional Public Safety
Training Center and Landfill.
East
HI
M-2
The land MR Tanner Mining, Inc purchased from the
City of Glendale in 2024 borders both the north and
east boundary of the Property. Additional mining
operations are located further east as well within
unincorporated Maricopa County and in the City of
Glendale up to the Glendale Municipal Airport
3
Land Use
Zoning
Existing Conditions
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.
Project Overview
The request herein constitutes Phase 2 of the overall project. 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 to the east, APN 501-55-012E, 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.
4
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 and maintained as open space. 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.
Phase 3 of the overall project will run roughly concurrent with the mining operation discussed in
Phase 2 above. Phase 3 will include the backfill of the existing Three Rocks mining operation
adjacent to the Property, which consists of over 300 acres, and will provide for the ultimate
development of the reclaimed land. The backfill operation for Phase 3 currently ongoing, but is
expected to continue for approximately 10 years until the land is prepared for development. This
timeframe is, however, dependent on market conditions and how quickly inert material can be
delivered.
Upon the conclusion of the mining activities and the completion of the backfilling operation, the land
will be developed and include a wide mix of uses, including a commercial corner at El Mirage Rd and
Glendale Ave, employment/flex uses along El Mirage Rd, and a combination of multifamily and
single-family residential uses at various densities. To complete this, Phase 3 of the overall project
will be annexed and rezoned upon the completion of the mining activities, which is expected to
conclude by the end of 2025. A land use plan is in the process of being completed for the
redevelopment of these 300+ acres, and is projected to provide for approximately 1,700 residential
units, over 15 acres of commercial, and over 30 acres of employment/flex uses.
It should be noted that approximately 80 acres of the area within Phase 3 is located within the City
of Phoenix annexation area due to a strip annexation the City of Phoenix completed along the
Bethany Home Rd alignment, bisecting the 308-acre property. Gilbert Blilie is coordinating with the
City of Phoenix to de-annex the strip annexation owned by Three Rocks LLC in order to annex and
develop the entire 308 acres owned by Three Rocks LLC within Phase 3 into the City of Glendale.
Phasing
The mining operation in Phase 2 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 will 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. The overall timeline for completion of the Phase 2 mining operation is
expected to run 7-12 years, depending on market conditions for aggregate materials over this time.
5
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. This proposed mining operation will
actually improve river hydraulics, establish more desirable riparian conditions, and may reduce the
extent of floodplain and floodway in the area.
All mines in Arizona located on private lands are required to obtain an ASMI-approved mined land
Reclamation Plan. This 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 and to a safe and geotechnically stable condition. The Reclamation Plan for this
mining operation will be prepared by Three Rocks LLC in consultation with the City of Glendale. ASMI
approval of the Reclamation Plan will require notification to the City of Glendale and the surrounding
community. Importantly, the estimated reclamation costs, as detailed in the approved Reclamation
Plan, are required to be bonded by Three Rocks LLC in the unlikely potential that Three Rocks LLC
cannot perform the reclamation as prescribed in the plan. So, the City of Glendale and the
surrounding neighbors can be assured that proposed improvements to the Agua Fria River corridor
will be completed.
6
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.
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
39 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
7
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 is entirely surrounded by active and approved sand and gravel mining land
uses. The approval of this request will 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, MR Tanner Mining, Inc/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.
Exhibit A
Legal Description and Exhibit
March 12, 2025
U:\_2025\25002205\SURVEY\DOCS\LEGAL\25002205 - THREE ROCKS LEGAL.docx
THREE ROCKS
PARCEL 2
LEGAL DESCRIPTION
A parcel of land situate within the west half of the west half of the Southeast Quarter of
Section 12, Township 2 North, Range 1 West of the Gila and Salt River Meridian, Maricopa
County, Arizona, also described as follows:
BEGINNING at the South Quarter Corner of said Section 12 monumented by a 3” Maricopa
County brass cap in hand hole, stamped S12, S13, T2N, R1W RLS 36563 dated 2003 from
which the Southwest Corner of said Section 12 monumented by a 3” Maricopa County brass
cap in hand hole stamped S11, S12, S13, S14, T2N, R1W Dated 2009 bears as the Basis of
Bearing North 89°28’15” West, 2,586.28 feet;
THENCE North 00°11'36" East along the north-south mid-section line of said Section 12, a
distance of 2,639.76 feet to the Center of said Section 12;
THENCE South 89°31'51" East along the east-west mid-section line of said Section 12, a
distance of 646.32 feet to the easterly line of the west half of the west half of the Southeast
Quarter of said Section 12;
THENCE along said easterly line South 00°11'17" West, 2,640.36 feet to the southerly line of
the Southeast Quarter of said Section 12;
THENCE North 89°28'40" West along said southerly line, 646.56 feet to the POINT OF
BEGINNING.
The above described parcel contains 1,706,611 square feet or 39.1784 acres more or less
and being subject to any easements, restrictions, rights-of-way of record or otherwise.
The description shown hereon is not to be used to violate any subdivision regulation of the
state, county and/or municipality or any land division restrictions.
Prepared by: Colliers Engineering and Design
2141 E. Highland Avenue, Suite 250
Phoenix, AZ 85016
Project No. 25002205
Date March 12, 2025
3/12/2025
N89°28'40"W
646.56'
N00°11'36"E 2639.76'
S89°31'51"E
646.32'
S00°11'17"W 2640.36'
M R TANNER MINING INC
APN: 501-55-012E
SOUTH QUARTER CORNER
SECTION 12, T2N, R1W
MARICOPA COUNTY
3" BRASS CAP DOWN 1.5'
STAMPED S12 S13 RLS 36563
SOUTHWEST CORNER
SECTION 12, T2N, R1W
MARICOPA COUNTY
BRASS CAP IN HAND HOLE
STAMPED 11,12,13,14 DATED 2009
BASIS OF BEARING
N89°28'15"W 2586.28'
NORTH EL MIRAGE ROAD
© 2025, COLLIERS ENGINEERING & DESIGN, INC.
DRAWN BY:
CHECKED BY:
PROJ.NO.:
SCALE:
DATE:
U:\_2025\25002205\SURVEY\DOCS\LEGAL\
25002205 - THREE ROCKS 501-55-011C.dwg
3/12/2025 2:11
2141 E. HIGHLAND AVE., STE. 250
PHOENIX, AZ 85016
P: 602.490.0535 / F: 602.368.2436
Engineering
& Design
Engineering
& Design
Formerly
THREE ROCKS
EL MIRAGE AND GLENDALE AVE.
GLENDALE, ARIZONA
EXHIBIT
25002205
MAR. 2025
1" = 400'
BMG
DMS
THREE ROCKS LLC
501-55-007D
NOT A PART
WESTERLY LINE OF THE
SOUHWEST QUARTER
OF SECTION 12
CENTER OF SECTION 12
NORTHERLY LINE OF THE
SOUTHEAST QUARTER
OF SECTION 12
EASTERLY LINE OF
THE WEST HALF OF
THE WEST HALF OF
THE SOUTHEAST QUARTER
OF SECTION 12
POINT OF
BEGINNING
3/12/2025
Exhibit B
Site Context
City of Glendale
Planning Area
City of Glendale
Planning Area
City of Phoenix
Planning Area
Litchfield Park
Planning Area
Three Rocks Context and Conceptual Phasing
0
0.25
0.5
0.13
mi
0
0.4
0.8
0.2
km
PHASE 2
Annexation and Mining Expansion
PHASE 1
Land Acquisition and Entitlement
PHASE 3
Backfill and Redevelopment
City of Phoenix Metropolitan
Planning Area Boundary
City of Glendale Metropolitan
Planning Area Boundary
N
Glendale Ave
Glendale Ave
Bethany Home Rd
El Mirage Rd
El Mirage Rd
Bethany Home Rd
P3
308 ac
P2
39 ac
P1
48 ac