I'd go even farther.
There should be no ability to interchange a GFCI breaker with a regular one in this case.
It's just as bad as Edison base fuses: anything into anything
--
How about instead if water contact electrical requires a smart controller with integral residual current detection. No separate GFCI. And in the case of water contact activities integral active stray current detection (like the "pool current hazard alarm" floaty devices, but built in to the water feature controller). A pool lighting or filter controller can do all this. Or if needed a "smart outlet" kind of like a GFCI but dedicated to the purpose of making safe the plug connected underwater lighting people seem to insist on using, and with the immersion sensor.
--
The old days when dumb shutoff devices were needed should long be gone. Your car's keyfob has a computer more powerful than the one that landed rockets on the moon. We can do better now!
640.44(B) hints at this "(A) Listed Units. Additional GFCI protection isn’t required for a listed self-contained spa or hot tub unit or listed packaged spa or hot tub assembly marked to indicate that integral GFCI protection has been provided for electrical parts within the unit or assembly." (Source Mike Holt's Article 680 ARTICLE 680 guide)
--
And while we're talking about removing code: 680.44(B) exceptions for heaters above 50A are highly suspect.
View attachment 2571066