Re: Shower Fans and Fan/light combos
This is the actual UL wording (GPVW):
Fans intended to be mounted over tubs or showers have been evaluated for such purposes and are marked "Acceptable for use over a bathtub or shower when installed in a GFCI protected branch circuit."
I see no height or distance exception in this wording. The 3' horizontally and 8' vertically specification does not exactly define what is "over" a bathtub or shower, but the AHJ could make that determinination and permit the exhaust fan to be installed without GFCI protection when outside of this area.