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existing stairwells. In general, the goals should be to allow existing spaces to have reduced building code thresholds for numerous building code standards.41 The Portland, Oregon, guide to "Converting Attics, Basements and Garages to Living Space" makes internal conversions of living space to create ADUs more feasible by adjusting several elements of building codes: • Ceiling heights • Exceptions to ceiling heights for beams, heating ducts, pipes • Sloped ceilings • Existing stairs • Noncompliantstairs • Stair landings • Firewall separation Achieving higher energy efficiency in buildings is a critical strategy for reducing greenhouse gases. But it can increase the cost or reduce the design feasibility of ADUs created by conversions of existing space. Conversions of basements and garages to ADUs are typically the most common type ofADU conversion. In the past, homes and garages were built with 2"x 4" stud walls versus the 2"x 6" framing used today, which accommodates much thicker insulation. Requiring a conversion to meet today's energy standards may require the replacement of all of the existing stud walls to provide sufficient wall cavity space to accommodate sufficient insulation and meet modern energy code. This interior stud wall or additional2" wall furring or exterior rigid foam insulation can add substantially ($5,000 to $20,000 in the Portland market in 2020) to construction costs and reduce the interior size of the living space of an already small dwelling. If the effect of these energy standards is that more large homes or new apartments are constructed the net effect might be to increase energy consumption in order to heat and cool the larger spaces and because of the embedded energy in the materials used for new construction. IV. ADU Application and Review Procedures There are many potential procedural challenges facing ADU applicants: complex regulations, complicated application forms and procedures, vague and discretionary standards that must be addressed by the applications, the length and complexity of the procedures for acting upon an application, and appeals from the initial decision on the application. A. Application Process Zoning regulations, even in small jurisdictions, are almost inevitably complicated. Even in mid -sized cities they can run to hundreds of pages. Unlike developers and homebuilders, many applicants forADUs don't have the resources to hire an attorney or consulting planner for more than a few hours to help them navigate the regulations and application process. In response, many local governments have developed simplified application forms, guidebooks, and online tools to determine whether and how an ADU can be sited on a property. This is a best practice recommended byAARP. See the Resources section for links to some examples. With the authorization and construction of more ADUs, more private sector specialists in ADU permitting are helping to fill this need. 44 1 HARP - Accessory Dwelling Units: Model State Act and Local Ordinance