In Arizona, the state lodging rules (A.A.C. R9-8, Article 13) require a lavatory, a shower room and potable water but do not name hot water. The duty comes from elsewhere: Maricopa County's plan-review guidance for residence accommodations and the plumbing code, which requires hot water at bathing and washing fixtures in residential occupancies like hotels.
Does Arizona's state lodging rule mention hot water?
No. The Arizona Department of Health Services' lodging establishment rules are in A.A.C. Title 9, Chapter 8, Article 13. They cover "hotels, motels, or tourist courts," defined in R9-8-1301 as a place that "offers two or more lodging units for lodgers to use in exchange for compensation" for "less than 30 consecutive days."
For plumbing, the Article says three things.
- Access to fixtures. Under R9-8-1303, "each lodger has access to a toilet, a lavatory, and a shower room," either inside the lodging unit or within 200 feet of an entrance to it.
- Fixture details. The same section's Table 13.1 also lists a floor drain connected to a sewage collection system and "potable water from all shower heads."
- Supply. Under R9-8-1305, the system must be "designed to provide sufficient quantity at a minimum pressure of 20 pounds per square inch at floor level at each bathroom, shower room, and permanent water fixture."
We read the Article's sections on definitions, general provisions, bathrooms, common areas, water supply, sewage and lodging units and found no sentence that sets a hot water temperature or requires hot water. That silence is not permission to run cold showers. It means the state lodging rule is not the source of the duty.
Where does the hot water requirement come from?
Two places: the plumbing code and county plan review.
The plumbing code. The 2024 International Plumbing Code, as adopted in Phoenix, says in Section 607.1: "In residential occupancies, hot water shall be supplied to plumbing fixtures and equipment utilized for bathing, washing, culinary purposes, cleansing, laundry or building maintenance." The building code decides whether a hotel is a residential occupancy. In the 2024 International Building Code, Section 310.2 puts "Hotels (transient)" in Residential Group R-1. Phoenix's published plumbing amendments (Ordinance G-7397) do not list Section 607 among the changed sections. Other cities adopt their own editions, so check the one where the hotel sits.
Maricopa County. The county's Environmental Services guideline on water heaters says "A continuous supply of adequate hot water, as stated in adopted codes, shall be provided in other permitted facilities (i.e., school grounds and residence accommodations)." The guideline also includes calculation worksheets for water heaters serving "Residence (Public) Accommodations." It is plan-review guidance for permitted facilities, so treat it as how the county reviews a design, not as a guest-facing right.
Keep two limits in mind. First, the guideline does not set a delivered temperature for guest rooms. Second, it points back to "adopted codes" for the standard to meet.
Can a hotel guest invoke Arizona's landlord-tenant law?
Generally not. The Arizona Residential Landlord and Tenant Act requires a landlord to "Supply running water and reasonable amounts of hot water at all times" (A.R.S. 33-1324(A)(6)). But A.R.S. 33-1308 lists arrangements "not covered by this chapter," and item 4 is "Transient occupancy in a hotel, motel or recreational lodging."
So the statutory hot water duty protects a long-term apartment tenant, not a nightly guest. A guest's practical options are to tell the front desk and ask for another room or a fix. Nothing here is legal advice. Someone staying in a hotel as their long-term residence should look at their specific agreement and ask a lawyer whether the Act applies.
What temperature should hotel water be?
The plumbing code limits the top end more clearly than the bottom. Shower valves must hold a maximum of 120°F under IPC Section 412.3. Where tempered water is used, Section 607.1.2 allows an ASSE 1070 limiting device set to no more than 110°F, a thermostatic mixing valve conforming to ASSE 1017, or a water heater conforming to ASSE 1082 or 1084. Our page on how senior living facilities prevent shower scalding walks through those valve rules, which apply to hotel showers too.
Maricopa County's guideline notes that "Temperatures at a plumbing point-of-use over 120°F are considered a safety hazard." It also says tempering valves let an establishment "maintain hot water at 140°F or higher" to reduce Legionella in the tank, then blend down at delivery. That is the arrangement the guideline describes. See our Legionella water management plan page for the reasoning.
What should a hotel manager do about a hot water complaint?
Treat it as a building system fault, not a guest preference.
- Check the room against its neighbors on the same riser. One room points at its fixture valve; a whole floor points at the loop or the heater plant.
- Confirm the recirculation pump is running. Our page on why an apartment building loses hot water on upper floors covers the same failure in a multi-floor building.
- Look at how the plant delivers hot water to the far rooms, covered in how hotels keep hot water at every guest room.
- Document the complaint and the fix. Records matter when a plan reviewer or a guest asks what happened.