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Committee pushes for verifiable 'but-for' and buffer analyses and evidence in pilot applications

Pilot Ad Hoc Committee (Shelby County Commission) · November 6, 2025

Summary

Members said pilot applications should include independently verifiable buffer/benefit-to-cost analyses, supporting receipts and documentation demonstrating the minimum incentive is needed — not just a developer's spreadsheet.

The ad hoc committee agreed that applications for pilot tax incentives should meet minimum requirements showing that incentives are necessary and backed by verifiable evidence.

"Show that the minimum incentive is needed, not just what the developer requested," Dr. Harrison said, urging a 'but-for' analysis and supporting documentation. Members said buffer analyses should include receipts and independently verifiable inputs rather than unsubstantiated spreadsheets.

Committee member Natalie McKinney recommended the application packet require a benefit-to-cost analysis and clear parameters for how the legislative body should review proposals. Janice Banks noted benchmarked practices in other jurisdictions informed several recommendations in the draft.

The committee identified key minimum requirements to place under 'creation' in the draft ordinance: (1) independently verifiable before-analysis demonstrating the incentive is necessary; (2) documentation and supporting evidence for buffer analysis; and (3) clear connection between incentives and public benefits such as affordable housing and job creation. The group asked staff to integrate the language into the working draft for legal review.

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