The California statewide Codes and Standards Enhancement (CASE) Team has proposed a major update for the 2028 Title 24, Part 6 code cycle that would expand pool heating requirements to existing non-residential pools whenever their heating systems are replaced.

What the Proposal Would Require

• Not a ban on gas heaters: Facilities could still use natural gas, but only as a backup.

• Mandatory “climate-friendly” alternative: Operators must install a solar system or multiple heat pump pool heaters as the primary system unless they qualify for limited exemptions.

• Duplicative systems: CASE acknowledges that gas will still be needed, meaning facilities could be forced to install both a new gas heater and costly alternative systems.

• High upfront costs: Examples show solar systems at schools and clubs costing over $200,000, with cost recovery assumed only over 25–30 years.

Who Is Affected The rule would apply to a wide range of community-serving pools:

• School pools (public and private).

• Community and municipal pools.

• Nonprofit facilities (YMCAs, Boys & Girls Clubs).

• Swim schools.

• Gyms, spas, and health clubs.

• Private clubs (golf, tennis, etc.).

• Water parks and resorts without overnight lodging.

Single-family, multifamily, and hotel/motel pools would remain exempt.

This means the proposal targets facilities that often run on limited budgets and cannot afford expensive retrofits.

Schools, community pools, and nonprofits could be forced to shut down or reduce access — a direct hit to swim instruction, drowning prevention, and community health.

The California Pool and Spa Association (CPSA) and Pool and Hot Tub Alliance (PHTA) support technically feasible and affordable climate- friendly alternatives. However, they oppose unfunded mandates that create financial barriers for facilities already struggling to stay open.

CPSA and PHTA are especially concerned that:

• Drowning is the leading cause of accidental death among children. Limiting access to swim schools and community pools will worsen this crisis, especially in underserved communities.

• Pools are vital for exercise, recreation, and youth sports. In areas like Sacramento, competition for pool time among schools, clubs, and teams is already intense.

• The proposal does not currently provide financial hardship exemptions, leaving many facilities without relief if costs are unmanageable.

CPSA met with the CASE Team on September 30 to highlight the risks to community-serving facilities and raised the need for exemptions covering:

• Financial hardship where compliance costs would force closure.

• Site limitations, such as lack of outdoor space for multiple heat pumps.

• Electrical infrastructure barriers, given each heat pump requires 50 amps and many facilities would need costly upgrades.

In parallel, CPSA is:

• Recruiting swim schools, YMCAs, and other community organizations to voice concerns, ensuring this issue is not framed as only an “industry objection.”

• Coordinating with partners like the U.S. Swim School Association (USSSA).

• Engaging with child safety advocates and drowning prevention groups to emphasize the public health impacts if pools close.

CPSA and PHTA filed written comments on October 20 and will file additional comments later this November with a more technical analysis.

CPSA will continue to advocate for amendments that protect access to pools while advancing California’s sustainability goals.

Look forward to updates and analysis of this important topic in upcoming issues of Service Industry News.