The pic reteams Polson with the Gotham banner, which produced the helmer's 2002 teen thriller Swimfan.
Adapted by scribe Emil Stern from the novel by Robert Cormier, Tenderness follows a teen serial killer and a 16-year-old runaway who can't resist the murderer's charm.
GreeneStreet is financially backing the pic and will produce along with Turtleback Prods.' Howard Meltzer.
Charles Randolph is exec producing the pic, which is skedded to go before the cameras early next year.
"Robert Cormier's novel is a sublime story. It is so rare to find a dramatic thriller about this age group," said GreeneStreet prexy John Penotti of the project.
Polson added that the pic "presents me with an opportunity to tell a distinctive and very moving story."