50 Roelker Road · Planning & Zoning Commission · August 17, 2026
Questions residents are asking for the record
These are the questions raised in writing to the City Engineer, the Zoning Enforcement Officer, the Planning & Zoning Commission, and the Board of Adjustment before the August 17, 2026 consideration of the consolidation plat. No violation is alleged. Each question asks what the City reviewed and approved, and where it appears in the record.
The request
That the item be tabled until the site plan is complete — not denied. The plan before the Commission does not show equipment the applicant itself disclosed to the State, and it states no structure heights at all.
1 · Equipment the plan does not show
In its own February 2025 application to the State for this address, the operator listed its equipment by number: 9A, Asphalt Cement Tank. 9B, Fuel Oil Tanks — plural. 10, Diesel Generators. 5, Asphalt Oil Heater. The State then required the dryer and the asphalt heater to burn only ultra-low sulfur diesel, and required a record of every shipment of fuel received. Fuel will therefore be delivered to this site and stored here.
Where is equipment 9B on the site plan the City approved? No fuel tank, capacity, containment structure, or fueling area appears on it. Neither do the diesel generators or the asphalt oil heater. Has the Fire Protection District’s Fire Marshal reviewed fuel storage or dispensing at this address, and is that review in the City’s file?
2 · Processing, not just mixing — M-1 or M-2, and by what right?
The operator’s own process flow diagram shows haul-in of recycled asphalt pavement, a RAP crusher, cold aggregate transfer, and a fired dryer before any mixing occurs. Raw rock and sand are crushed and dried on site. That is material processing, and it is what determines how the use is classified under the zoning code.
This property is zoned M-1. The Code separates the districts by what happens to the material: §405.560 sets out the M-1 uses, while the processing of raw materials is addressed under M-2 in §405.570. Crushing rock and drying raw sand and aggregate in a fired dryer is not the handling of a finished product. And the Code’s definition of a use in §405.090 is written to reach the whole operation: “the specific purpose or combined purposes for which land or a building is designed, arranged, intended, occupied or maintained, with any combination of uses subject to the like combination of their individual requirements.” So the plant cannot be classified by one label while its crushing, drying, heating, and fuel storage go unexamined.
Identify in writing the specific provision that authorizes this operation as a permitted M-1 use by right — and do so for the whole development, not the mixing step or the product recipe alone. The classification should address, component by component: the crushing of rock and recycled asphalt pavement; the drying and heating of raw sand and aggregate in a fired dryer; the asphalt oil heater and its heat source; the fuel oil tanks, their capacity, containment and dispensing; the diesel generators, including any standby or emergency generation; the open stockpiles of raw material; the silos, stack and other vertical structures and their heights; and the surfacing and drainage beneath each of them. State how each of those fits the M-1 provisions of §405.560 rather than the processing of raw materials addressed under M-2 in §405.570. If an asphalt plant is not expressly listed among the permitted M-1 uses, how does the approval satisfy §405.080(A)(2)(c) and §405.100(A)(7)(e), which require a Planning & Zoning determination of similarity and compatibility and a formal amendment procedure before an unlisted use may be authorized? Which equipment description did the City rely upon in classifying this use, and where in the file does it appear?
3 · Height — the plan states none
Section 405.100(A)(2)(a) limits non-dwelling structures to thirty-five feet, provides that nothing other than authorized utility towers and antennas may exceed fifty feet in any district, and requires one additional foot of setback for each foot of added height. No claim is made here that any structure is too tall. The plan contains no height dimension for any structure and no elevation drawing. Some components may well be exempt, but an exemption is applied to a number, and there is no number to apply it to. Setbacks cannot be checked without heights.
4 · Current authority to operate at this site
The State’s March 12, 2025 authorization for this plant at this address states on its first page: “Authority to operate at this site expires on April 1, 2026.” A special condition also bars operation at any one site for more than twelve consecutive months, in order to preserve the equipment’s status as portable nonroad engines. No suggestion is made that anyone is operating unlawfully — an extension may exist that residents have not seen. What is the applicant’s current authorization to operate at 50 Roelker Road, when was it issued, and is a copy in the City’s file?
5 · The one place the Code names an asphalt plant
Chapter 405 names an asphalt batching plant in exactly one place, under Temporary Uses: “Temporary Asphalt Or Concrete Batching Plants. These uses are permitted in any district when part of a local construction project.” Temporary uses are allowed “upon issuance of a permit specifying time limit.” A permit carrying a stated time limit is not a use by right, and both readings cannot hold at once: if an asphalt plant were already permitted by right in M-1, that provision would be unnecessary.
Under which provision of Chapter 405 is this plant authorized? If it is the Temporary Uses provision, which local construction project, which permit, and what time limit? If it is not, under what listed M-1 use was it approved by right?
6 · The City’s own precedent: gravel at an asphalt plant required a variance
On January 16, 2025 the City published a notice, signed by the City Clerk, for a Board of Adjustment public hearing held January 29, 2025:
“Star Connection Drive, Wright City, Missouri. Applicant Greg Karrenbrock seeks a variance from the paving requirement of the Wright City Zoning Code, Section 405.110.C.1. ‘Off-Street Parking and Loading Requirements’, to allow gravel surfaces for a proposed asphalt batch plant.”
Three things follow from the City’s own document. That subsection applies to an asphalt batch plant, not only to parking lots. Gravel surfacing at such a plant is not compliant without relief. And the route to relief is the Board of Adjustment, by variance, at a noticed public hearing where neighbors may speak.
The approved project set for 50 Roelker Road proposes gravel — for the parking and material-handling areas. Its Site Legend lists a “Gravel Limit” alongside “Concrete Limit” and “Asphalt Limit,” and its sheets label a “Material Haul Road — Gravel” and a “Gravel Parking Lot.” In fairness to the record, the entrance itself is specified as paved — sheet C-6, “Entrance Detail,” calls for asphalt pavement with a 2.5″ top coat over 8″ of clean rock, plus entrance concrete pavement. The open question is the parking lot and haul road, and the City has confirmed in writing that no variance application exists for this project. Separately, the civil site plan revised in July 2026 for the new entrance locations was produced as an image-only document, so whether C-6 still governs the relocated entrances cannot be verified from the record as released.
The exceptions in §405.110(C)(1) are written narrowly: existing residential gravel driveways; residential driveways connected to private gravel roads; a conditional use permit “to allow heavy steel track equipment storage on gravel”; and “biodegradable product inventory and materials” in industrial districts. Nothing here is residential. The heavy-equipment route requires a conditional use permit, and the City has confirmed no such application exists. Rock, sand and liquid asphalt cement are not biodegradable. The main rule states without qualification that “all driveways and access points to public or private streets shall be paved.” If an exception applies, which one, by subsection?
7 · Where are trucks cleaned, and where does that runoff go?
At hot-mix plants, truck beds are commonly cleaned with diesel fuel so asphalt will not stick. In common industry practice the driver soaks the bed with diesel from a hand sprayer or a pump drawing off the truck’s own fuel tank, and then, on arriving to load, raises the bed to check it — releasing that diesel, along with diluted asphalt, onto the ground at the loading area. That is why looking for a wash bay on the plan may be the wrong question: the release happens where trucks stage and load. Diesel and asphalt residue of that kind soaks into soil rather than washing away.
Two related points follow. Incoming material also bleeds: recycled asphalt pavement and ground shingles release residue where they are stockpiled. And berming does not solve it — a berm holds liquid on site, where it moves downward into the ground instead of running off. The site drains toward an outfall with a stream beyond.
Where on this site are truck beds cleaned or released, and is that area a hard surface or gravel? If paved, where is that pavement shown on the plan, and where is its drainage directed? If gravel, what was approved for it — and how does that square with §405.110(C)(1) and with the variance the City required for gravel surfaces at the Star Connection asphalt plant? What surfacing, containment, and treatment did the City review for the loadout and staging area, and for the RAP and shingle stockpiles? If the City’s position is that no such cleaning or release occurs on site, residents ask that it be stated in writing.
Residents further ask that the City require groundwater monitoring wells around the perimeter of the site as a condition of any approval, sampled on a stated schedule with results filed as public records, so that leaching of petroleum and asphalt constituents into soil and groundwater can be detected rather than assumed absent. Establishing baseline conditions before operations begin protects the operator as much as the neighbors: without a baseline, no one can later say what this operation did or did not cause.
8 · The record behind the approval
The City’s engineer billed the Roelker Road planning study as 75.00% complete on a $23,850 contract in June 2026, and the City has separately confirmed in writing that no final traffic study exists. The City has also stated “no responsive records” as to permits, while a water permit and a stormwater permit have been confirmed to exist against the earlier six-lot configuration that predates this consolidation. And §405.100(A)(7) requires the supplemental regulations to be reviewed in every case in which a land use is considered, including an assessment of the desirability of the use’s location. Does a record of that review exist for this plant?
The full text of the letter, the operator’s State filings, the January 2025 hearing notice, the site plans, and the City’s written responses are posted at
the records page. The residents’ petition concerning this approval remains open and pending; its full record is at
Petition, Volumes I–IV.
Page current through August 17, 2026.