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Surprise Local Amendment

Drinking fountain requirements in Surprise, AZ: the 50 occupant rule and water coolers

Verified November 11, 2026
In Short

In Surprise, a building with an occupant load of 50 or fewer needs no drinking fountain, where the model code stops at 15. Restaurants that give free water in a cup need none. Everywhere else fountains are required, Surprise lets bottled water dispensers or water coolers stand in, and it struck the model code's 50 percent cap on that swap.

Official Source
City of Surprise: Local Amendments to the 2024 International Codes and the 2023 National Electrical Code, January 1, 2026 (PDF)
Surprise Local Amendments to the 2024 International Plumbing Code, Sections 410.2 and 410.4, and to the 2024 International Building Code, Section 2902.6 (effective January 1, 2026)
“In other occupancies where drinking fountains are required, bottle water dispensers or water coolers shall be a permissible substitute.”
Applies to:
Owners, tenants, designers and plumbing contractors on commercial projects in Surprise that must provide drinking fountains, from small offices and shops to schools, gyms and churches
Official fee:
not applicable; drinking fountains are part of the plumbing permit and plan review for the job
In force:
2024 International Plumbing Code and 2024 International Building Code with Surprise local amendments, effective January 1, 2026 (Surprise Municipal Code Sec. 105-19), since January 1, 2026
Last verified:
November 11, 2026, against the official page

Surprise changed two drinking fountain rules when it adopted the 2024 codes on January 1, 2026. Small buildings get a bigger break: no fountain is required at an occupant load of 50 or fewer, where the model code stops at 15. And where fountains are required, Surprise lets bottled water dispensers or water coolers take their place without the model code's 50 percent limit. Restaurants that hand out free water in a container still need no fountain at all.

What does Surprise's code say?

Surprise's amendments show each change as struck and underlined text. Three sections touch drinking fountains.

IPC 410.2, Small occupancies. The model code reads "Drinking fountains shall not be required for an occupant load of 15 or fewer." Surprise struck 15 and wrote in 50.

IBC 2902.6, Small occupancies. The building code carries the same sentence, and Surprise made the same change there, from 15 to 50. The two codes now agree, so a plan reviewer reading either one gets the same answer.

IPC 410.4, Substitution. The first sentence stays: "In restaurants that provide drinking water in a container free of charge, drinking fountains shall not be required." The second sentence is struck. It said water coolers or bottled water dispensers "shall be permitted to be substituted for not more than 50 percent of the required number of drinking fountains." Surprise replaced it with: "In other occupancies where drinking fountains are required, bottle water dispensers or water coolers shall be a permissible substitute." The new sentence names no percentage.

Section 410.3, which asks for one fountain for people who use a wheelchair and one for standing people where fountains are required, is not on Surprise's list of amendments, so the model text still applies wherever fountains are required (a reading).

What do the key terms mean?

  • Occupant load: the number of people the building code says a space is designed to hold, worked out from its floor area and use. It is on the plans, not a head count on a busy day.
  • Drinking fountain: a plumbed fixture with a bubbler you drink from directly.
  • Water cooler or bottled water dispenser: a unit that pours water into a cup or bottle. Surprise's wording does not say it must be plumbed, so a jug cooler reads as allowed (a reading; confirm it with the plan reviewer).
  • Bottle filling station: a plumbed unit that fills a bottle. It fits the dispenser wording in practice (a reading).

Who does this cover?

Commercial and public buildings in Surprise built or altered under the 2024 codes: offices, retail, restaurants, schools, gyms, churches and tenant improvements. Single-family homes are not covered; these sections are written for commercial and public buildings.

Quick check: does your space need a fountain?

SituationWhat Surprise expectsWhy
Small office or shop, occupant load 50 or fewerNo drinking fountain requiredIPC 410.2 and IBC 2902.6 as amended
Restaurant that gives free water in a cup or bottleNo drinking fountain requiredIPC 410.4, first sentence
Office with an occupant load of 180Fountains required, and a water cooler may count for themIPC 410.4 as amended, no 50 percent cap
Same office in ChandlerA dispenser can cover at most half the countChandler City Code 29-4.3
A fountain is installed anywayIt must meet the ADA, high and low units where requiredADA Standards Section 211 and IPC 410.3
Designer wants a bottle filler to be the accessible unitNot by itselfThe Access Board says a bottle filler cannot stand in for a wheelchair or standing fountain

What does this look like in real life?

  • A 2,500 square foot insurance office. At the building code's 150 square feet per person for business use, its occupant load comes to about 17. Under the model code's limit of 15 it would need a fountain. In Surprise it does not.
  • A gym moving into a former grocery suite. Its occupant load is well over 50, so fountains are required. The owner wants bottle fillers and a water cooler instead of bubblers. Surprise's wording allows the swap without a cap. Any fountain the owner still puts in is built to the ADA, and the plan reviewer settles the count.
  • A sit-down restaurant. Servers bring water to every table at no charge, so the dining room needs no fountain under the first sentence of 410.4.

What should you do next?

  1. 1Find the occupant load on your plans. If it is 50 or fewer, Surprise does not require a drinking fountain.
  2. 2If it is over 50, work out the required number from the plumbing code's fixture table for your use.
  3. 3Decide whether coolers, bottle fillers or fountains will meet that number, and show the choice on the plumbing plan.
  4. 4If you install any fountain, plan it to the ADA: a wheelchair height unit and a standing height unit, or one unit that serves both.
  5. 5Submit the plans through the City's permit process and ask the plan reviewer to confirm the substitution before you order fixtures.

What do people get wrong?

  • "Every business needs a fountain." Not in Surprise below 51 occupants.
  • "A cooler can only cover half." That is the model code and Chandler's rule. Surprise struck the 50 percent limit.
  • "A bottle filler makes the fountain ADA compliant." The Access Board says a bottle filler cannot replace the wheelchair or standing fountain.

When to bring in a plumber

A fountain or bottle filler needs a water line, a drain, and a spot on the wall where the ADA clearances work. That is easiest to plan before the walls close. A plumber who does commercial work in Surprise can read the fixture count off your plans, tell you where a cooler can stand in for a fountain, and rough in the lines for the units you keep. HQ Plumbing & Air does commercial plumbing in Surprise. See our commercial plumbing and Surprise plumbing pages, our guide to drinking fountain and bottle filler rules in other Valley cities, or contact us to talk through a project.

How Do Other Valley Cities Handle It?

WhereWhat appliesSource
ChandlerChandler keeps a cap. A water dispenser connected to the potable water system can be the first required fountain, and any dispenser can replace not more than 50 percent of the required number.Chandler City Code 29-4.3 (IPC 410.4 as amended)
Verified September 29, 2026
ScottsdaleScottsdale goes the other way: every drinking fountain must have a water dispenser (bottle filler) built in or installed next to it.Scottsdale Revised Code Sec. 31-83 (IPC 410.1.1 added)
Verified October 4, 2026
Paradise ValleyParadise Valley, still on the 2015 IPC, uses nearly the same words as Surprise: in other occupancies where fountains are required, bottle water dispensers or water coolers may be substituted.Paradise Valley Town Code 5-5-2(B)
Verified October 4, 2026

This page explains the rule. The official text at the source above governs.

Sources
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