NOVEMBER 2025 I VOL. 42, NO. 11
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In this Issue: Why Pickleball Noise Is Different I The Role of Local Staff and Depart ments I Tools for Mitigating Pickleball Noise I Designing the Zoning Amendment I Variances and Conditional Review I Conclusions
A spatial
comparison of
tennis, pickleba/1,
and basketball
courts (Credit:
Nicholas Klein/
iStock/Getty
Images Plus)
I
Managing Pickleball
Noise Through Zoning
By Charles Leahy
What began as a friendly, fast-growing sport has become a recurring source of conflict in communities across North America. Fueled by low cost, wide appeal, and minimal space requirements, pickleball has quickly become a must have recreational land use often shoehorned into parks, clubs, and residential areas with little foresight. But with the sport's rise has come an unexpected backlash, as neighbors report escalating noise, declining property values, and a deteriorating quality of life.
What's become clear is that zoning
codes are unprepared and do not have
provisions specific to this new and unex
pected noise. With an estimated 20,000
separate zoning authorities in the U.S.,
there is considerable work ahead.
This issue of Zoning Practice offers a
framework for planners and local officials
seeking to amend existing zoning ordinances
in a way that balances demand for pickleball
courts, neighborhood compatibility con
cerns, and legal risk. It begins by highlighting
common triggers for conflict before identify
ing the acoustic characteristics that
differentiate pickleball from other common
recreational activities, explaining why local
noise ordinances are the wrong tool for the
job, and outlining an alternative approach to
regulating court siting through special per
mits, setbacks, and use-specific standards.
Zoning Practice I American Planning Association I November 2025 2 Why Pickleball Noise Is
Different
Media coverage and lawsuits have brought
the issue into sharp focus. One common
trigger for conflict involves municipal or
county parks. The recreation department
creates pickleball courts and encourages
play, while nearby residents demand relief.
The resulting tension spills into city council
meetings, with public comment periods
filled by dueling factions of players and
neighbors. Conflict escalates as residents
call for noise ordinance enforcement, and
public records requests are filed by both
sides.
Another common trigger involves pri
vate facilities, where planners and local
officials have tried to manage court con
struction or respond to complaints using
existing zoning tools. These efforts have
led the city into litigation with the court
owners, exposing the limits of outdated
zoning never designed to address the
scale or acoustic profile of pickleball.
Noise concerns often arise when
existing tennis courts are converted for
pickleball play. In many cases, these con
versions have been reversed, with cities
or clubs restoring the courts to their orig
inal tennis use in response to neighbor
complaints. This pattern of converting,
encountering problems, and reverting sug
gests that the differences between tennis
and pickleball are not superficial, they are
central to understanding the nature of
incompatibility.
The Sound of Pickleball
Unlike tennis, which features a soft ball
and a racquet with flexible strings, pick
leball involves hard plastic balls and
solid-faced paddles. With smaller courts
and less running, player competence
is quickly achieved, and fast paced
exchanges create paddle strike rates of
up to 900 hits per hour per court. With
four courts placed on a repurposed tennis
footprint, the result is 3,600 sharp "pops"
per hour, echoing in random succession
for hours, often dawn to dusk.
Here is an actual audio recording of
play on four pickleball courts, 65 feet from
neighboring residences: audio of pickle
ball noise from 4 courts.
While tennis is typically quiet and for
mal with fewer players per court, pickleball
is more social and group-oriented, mostly
a doubles game. Players drop in with-
out set schedules, leading to clusters of
active pickup games and groups waiting
nearby. The informal and highly social
nature contributes to more frequent shout
ing, laughter, and other vocalizations that
amplify the overall noise impact.
While other recreational uses, such as
playgrounds and basketball, can generate
noise, their impacts are self-limited by the
school and work schedules of the users.
In contrast, pickleball is especially popular
among seniors and retirees who gather to
play in the early morning hours. This is
compounded by a younger after-work
crowd that fills the courts in the evenings
and on weekends, resulting in near-contin
uous daily use and prolonged noise
exposure to nearby residents.
.Acoustic Properties That Matter
The human response to pickleball noise is
driven by an unusual combination of par
ticularly intrusive qualities:
• Sound Pressure Level (Decibels):
Commonly understood as loudness,
pickleball paddle strikes are approxi
mately 20 decibels louder than tennis,
which-due to the logarithmic nature
of the decibel scale-represents a
fourfold increase in acoustic energy
and is perceived by listeners as dra
matically louder, especially in quiet
residential settings.
Doubles play on a I
pickleba/1 court in a
public park (Credit:
pics721 /iStockl
Getty Images Plus)
Zoning Practice I American Planning Association I November 2025 3 I Table 1: Nuisance Noise from a Dog Kennel vs. Pickleba/1 Courts Kolle Cllaraoteztatla l>ogB'.emlel Plc:klel,all
Loudness How upset is the dog? How hard did the paddle hit the ball?
Each paddle and ball combo has
Variation Growl, bark, whine, yap its own impulsiveness, tone, and reverberation
Depends on the number of dogs, the 15 pops per minute per active Number Predictability
Exposure
temperament of each dog, and the
frequency of triggering conditions
Unpredictable
Random and intermittent
• Impulse Noise: With a fast attack
and short decay within 2 milliseconds
(.002 seconds) followed by a rever
berating tail of 20 milliseconds , the
impulse created by a paddle strike
crests at a peak level substantially
above the background noise, making
these sounds startling and difficult to
ignore.
• Acoustic Frequency: Each pad-
dle strike is centered around 1,250
Hertz-where human hearing is most
sensitive-making them subjectively
more annoying.
• Lack of Spectral Masking: The
random staccato pattern stands out
sharply, unlike the steady hum of
urban noise.
• High Rate Repetition: Each court
generates 900 pops per hour, and
with multiple courts, the daily noise
exposure can be many thousands of
individual noise events.
• Propagation Characteristics:
High-frequency impulsive sounds
reflect and travel efficiently; landscap
ing and fencing provide little relief,
while nearby structures and pave
ments can unintentionally amplify and
redirect the sound up to 1,000 feet.
court
Persistent during core hours,
random during slow hours
Often 12 to 15 hours per day
under favorable weather
conditions
The JBioloigry of Anll'l.oyaXilce
Impulsive noises-sudden , sharp, and
irregular-trigger an inherited physiological
response deeply rooted in human survival.
The sudden breaking of a branch in the
woods, for example, activates the endo
crine system's "fight or flight" response-a
mechanism that evolved to help early
humans detect and react to threats.
This neurological alarm system is deeply
inbred, involuntary, and it cannot be simply
ignored.
With repeated and prolonged expo
sure, the body's stress-response systems
remain activated, leading to a cascade of
negative health outcomes. Over time, this
results in not only psychological distress
such as anxiety, irritability, and
fatigue-but also physiological harm,
including elevated cortisol levels, disrupted
sleep patterns, and cardiovascular strain.
In short, the noise violates the body, mak
ing it an inherently incompatible use near
residential dwellings.
Why Traditional Noise
Ordinances lF'ail
A natural response to complaints is to
enforce the local noise ordinance. But this
approach has repeatedly failed.
Zoning Practice I American Planning Association I November 2025 4 Most local noise codes rely on A-weighted
decibel limits designed for continuous,
broadband sounds such as traffic, music,
and general urban activity. However, when
applied to the impulsive noise of pickle
ball, these measurements significantly
understate the true impact-often result
ing in readings that fall below enforceable
thresholds, despite clear community dis
turbance.
Local enforcement officers do
not have the specialized equipment
and training for measuring impulsive
noises. Enforcement is reactive and
complaint-driven , placing the burden
on residents. Departments tasked with
enforcement-such as code compliance
or law enforcement-are limited to issuing
a citation, ultimately involving prosecutors
and judges when the violator does not
agree to pay the fine. When the courts are
publicly owned it is politically and institu
tionally difficult to issue citations against
the city recreation department.
The Role of Local Staff and
Departments
Understanding the distinct roles and lim
itations of local government departments
is crucial to assessing the present situation
as well as crafting future policy.
Recreation Department: Serving
Demand, Not Preventing Conflict
Recreation departments manage parks
and prioritize access and user equity.
Community engagement-often via online
surveys-can elevate pickleball as a must
have top priority, sometimes based on
feedback from nonresidents or sport
advocates. However, recreation depart
ments are not experienced with managing
land use compatibility . Poor choices have
often led to eventual court closures and
return to tennis, but often only after years
of ongoing controversy.
Code Enforcement : Too Little , Too
Late
Code enforcement is reactive. It often
lacks jurisdiction or tools to address impul
sive recreational noise. Where complaints
are substantiated, enforcement can still
be slow, politically fraught, and ineffec-
tive, especially when local recreation
departments are the source of the nui
sance'. Without clear standards tailored to
pickleball's unique sound profile, enforce
ment staff struggle to take meaningful
action. The result is frustration on both
sides and a lack of resolution.
Planning Department: A
Preventive, Structured Approach
The planning department has the right
tools and experienced staff to prevent
conflict. Zoning codes allow for use clas
sifications, setbacks, conditional use
permits (CUP), and variances-all applied
through a transparent process with
hearings, staff reports, and public input.
This ensures thoughtful, consistent deci
sion-making grounded in the purpose of
the ordinance-protecting public health
and welfare by separating incompatible
land uses. Planning commissions and zon
ing boards also offer forums for appeals
and public oversight, which helps maintain
legitimacy.
City Attorney: Legal Risk
Management
The municipal attorney plays a vital role
in drafting enforceable ordinances and
defending decisions . Poorly sited courts
on city land can expose local jurisdictions
to litigation under nuisance law. Legal
counsel can help avoid costly errors and
ensure that regulations withstand judi-
cial scrutiny. Municipal attorneys are well
versed in the local zoning ordinance and
can craft amendments needed to incorpo
rate pickleball planning.
Local Legislative Body : Reducing
Political Risk
Without a comprehensive zoning ordi
nance, the legislative body becomes the
forum for ad hoc decisions, eroding public
trust and drawing elected officials into
controversy. Elected officials benefit when
land use disputes are addressed through
Zoning Practice I American Planning Association I November 2025 5 I
A dedicated
indoor pickleba/1
facility in Mount
Prospect, Illinois
(Credit: patty_cl
iStock Unreleased)
a formal process managed by experienced
planning staff rather than public outcry or
case-by-case appeals and media atten
tion.
Tools For Mitigating Pickleball
Noise
A suite of noise control tools is available,
but each comes with trade-offs. Effective
design of the zoning ordinance begins with
a realistic understanding of how each tool
works in practice.
Complete Xl1ulloor Enclosure
When courts are fully enclosed within a
building, exterior noise emissions can be
reduced to negligible levels. Cities may
wish to incentivize indoor development by
granting such uses by right, without the
need for a conditional use permit. Alterna
tively, cities may issue CUPs with simple
operational conditions, such as requiring
all doors to remain closed during play and
prohibiting any amplified music or
announcements outdoors of the building.
Distance ai.xa<dl. Sefbacks
Sound energy diminishes naturally with
distance. Setbacks are especially powerful
because they impose no additional cost
on developers and require no enforcement
mechanism. As a result, a well-calibrated
setback standard is the most effective and
reliable zoning tool available. A substantial
starting setback can give the other mitiga
tion solutions a better chance of success
by guaranteeing a partial dissipation of the
noise.
!Baniers and Wa.Us
Sound walls are a common response to
community complaints, but their effec
tiveness depends heavily on materials,
location, and design. A fundamental mis
understanding is to visualize sound as
a linear "bullet" that can be blocked by
a line-of-sight obstacle. In truth, sound
energy radiates outward from the paddle
in a three-dimensional bubble, rising and
spreading in all directions. This allows
sound to flank over the top of barriers.
Typical barriers stand at least 10 feet tall,
leading to high construction costs and
conflict with fence height limits in resi
dential areas. Barriers also impair airflow
and reduce visibility for players, neigh
bors, and police departments. Barriers
cannot protect two story homes. Despite
these limitations, barriers may still play a
supporting role when combined with ade
quate setback distances.
Zoning Practice I American Planning Association I November 2025 6 Quiet Equipment
Innovations like the OWL (Optimized Whis
per Level) paddle and the Librarian quiet
foam ball offer meaningful reductions in
loudness, frequency, and general annoy
ance. However, acceptance remains low,
which leads to significant enforcement
difficulties. Players prefer to use their
own equipment, and facilities struggle to
enforce quiet paddle mandates without
dedicated staff. And yet in commercial or
membership-based settings, and even
public parks, a CUP can mandate the
hiring of onsite supervisors and thereby
prohibit personal paddles and mandate
on-site rental or checkout of pre-approved
quiet paddles and balls.
Hours and Days of Operation
Time-of-day and days-of-play restrictions
can be effective but hugely controversial. The
difficulty is that the weekends, holidays, and
evening hours are the most intrusive noise
burdens on neighbors because ambient
noise is lower, and residents expect rest and
recovery from the stresses of work, school,
and weekday activity. At the same time,
players put a high value on 10- or 12-hour
days of play, seven days a week. Operators,
whether a recreation department or private
party, are deeply resistant to having an
underutilized facility.
To be effective, experience has shown
that real periods of no noise, including
entire quiet days and substantial hours
of quiet on certain days of the week, can
help the neighbors tolerate the noise
and demonstrate the local jurisdiction's
commitment to residential well-being. For
example, limiting the hours to 1 O hours,
seven days is not an effective limitation.
Providing no play after 6 p.m. and no
play on Sunday can be more effective.
Code enforcement officers and police can
enforce clearly stated playing hours.
Player Voices
By its nature and culture, pickleball is a
boisterous activity. Even with quiet-play
rules, players are largely powerless to rein
in the spontaneous outbursts, laughter,
and on-court banter that define the joyful
culture of the game. Distance remains the
most practical and reliable solution.
Practicality of Mitigation Tools by
Ownership Type
Noise mitigation strategies must be tai
lored to the practical realities of the zoning
applicant. Planners and local officials
should anticipate different types of appli
cants and be ready to craft conditional
permits accordingly.
Zoning Practice I American Planning Association I November 2025 7 Public Parks and Recreation Districts
Publicly owned parks often involve four,
eight, 12, or more courts clustered for
tournament or league play. These are
often open for extended hours of 10-12
or more hours daily and have high inten
sity of use. Players often drive from long
distances from other cities, increasing
overall traffic and usage levels. In these
cases, enforcement of quiet equipment is
difficult, unless the park employs rangers
with both presence and authority . Barriers
are expensive and may be cost-prohibitive.
Instead, the local planners and officials
should favor large setbacks as the inten
sity of usage guarantees complaints from
close-in neighbors. Experience shows
that violation of posted hours should be
expected unless the courts are fenced
and locked.
Commercial Developers and
Franchises
Developers often repurpose big-box
retail spaces and other underutilized
buildings, offering soundproof play in a
climate-controlled environment. However,
when developers also propose outdoor
courts, the CUP should require substantial
setbacks , use of quiet paddles, and clear
hours of operation. Equipment rentals and
loaners can be enforced and ensure that
only low-noise gear is used.
Private Membership Clubs and
Country Clubs
These applicants often have well-re
sourced boards and legal teams . They
may resist restrictions and lobby or litigate
for exceptions. CUP conditions should
treat these uses like any other, requiring
compliance with setbacks, limited hours,
and noise mitigation strategies. Clubs
are often able to enforce quiet equip
ment rules and limited hours since player
access is already restricted by member
ship requirements.
Private Residential Installations
Difficult cases arise when individual
homeowners play pickleball on their pri
vate lots. Given the potential for chronic
neighborhood disturbance, planners and
officials may choose to prohibit private
courts altogether in residential zones. As
a minimum, these courts should meet the
same conditions applied to other recre
ational facilities: setbacks, hours of use,
and possible equipment restrictions . The
zoning provisions should clarify that both
permanent and temporary pickleball activ
ity (such as lining a basketball court or
driveway and bringing in portable nets) are
subject to the same zoning scrutiny.
Homeowners Associations
Homeowner associations (HOAs) were
designed for land use efficiency, with
tennis courts placed near homes without
issue. When those courts are converted to
pickleball, the noise impact changes dra
matically, and conflict erupts. Residents of
HOAs deserve the same health and safety
protection that the governing jurisdiction
provides in other neighborhoods. Con
sistent zoning and permitting processes
are needed as internal HOA governance
leaves too many citizens without meaning
ful recourse.
Designing the Zoning
Amendment
Cities across the country are beginning
to confront the land use and noise con
flicts created by outdoor pickleball. Some
leading examples are Torrance, Califor
nia (Ordinance No. 3931): Centennial,
Colorado (Ordinance No. 2023-0-1 O):
Park City, Utah (Ordinance No. 2022-
.QID; Sagaponack, New York (§245-34.S );
and Easttown Township, Pennsylvania
A moment of I spontaneous
exuberance during
a pick/eba/1 match
(Credit: kali9/E+)
Zoning Practice I American Planning Association I November 2025 8 (Ordinance No. 469-25). No single ordi
nance stands out as a definitive model,
but taken together, these first movers offer
a framework of best practices.
Define Pickleball as a Distinct
Land Use
The zoning ordinance should explicitly
define pickleball as a distinct, noise-gener
ating land use. This definition may take the
form of classifying "pickleball play" as its
own land use category or as a specialized
subcategory within outdoor recreational
facilities. Importantly, the definition should
encompass both permanent courts-with
fixed nets and painted lines-and tem
porary setups, such as portable nets
wheeled onto driveways, tennis, or basket
ball courts.
The regulatory trigger
should be the noise-pro
ducing activity itself, not
just the construction of a
fixed facility. This approach
allows a proper response
to unpermitted temporary
play when it results in
significant neighborhood
impacts.
Require Zoning and
Permits for Publicly
Owned Courts
A critical component is
ensuring that munici
pal-owned courts and
those operated by inde
pendent park districts
within the local jurisdiction
are captured within the
scope of this land use
definition. Applying the
same zoning standards
to publicly owned facil-
ities promotes fairness,
reduces community
conflict, and reinforces public trust in the
commitment to neighborhood livabil
ity-particularly given that public courts
account for a significant share of the
nationwide problem.
Define the Noise-Sensitive
Receptors to Be Protected
A zoning amendment should specify that
the following nearby land uses are con
sidered "noise-sensitive" and entitled to
protection from intrusive noise levels:
• Residential properties (including non-
conforming or legacy residential uses)
• Schools
• Senior living facilities
• Hospitals and medical offices
• Religious institutions
• Professional offices that depend on
quiet environments
These land uses are especially vulnerable
to impulsive noise, which can disrupt rest,
learning, concentration, speech compre
hension, and emotional recovery-core
functions of these environments.
Establish the Distances for a
Three-Tiered Permitting Structure
A promising structure gaining traction is a
three-tiered permitting approach based on
proximity to noise-sensitive uses:
• Prohibited Zone: A setback distance
and buffer zone where outdoor pickle
ball is simply not allowed.
• Conditional Use Zone: An inter
mediate distance where courts may
be approved with mitigation, public
notice, and discretionary review.
• By-Right Zone: A distance at which
courts may be allowed without special
review if zoning criteria are met.
This approach offers clarity, adminis
trability, and a defensible connection to
acoustic realities, helping planners and
local officials prevent conflict altogether
where the risk is high, manage impacts
where distances are marginal, and streamline
approval where distance alone provides a
reliable degree of reduced conflict.
Prohibited Zone
In this inner zone, typically a specified
distance of 250, 350 , or 500 feet, out
door pickleball courts should be outright
prohibited due to the certainty of incom
patible land use and the low probability of
other mitigations to fully resolve the conflict.
Choosing a relatively large distance such as
350 or 500 feet will provide maximum pro
tection and reduce the number of conflicts.
Zoning Practice I American Planning Association I November 2025 9 Conditional Use Permit Zone
In the middle zone pickleball may be
allowed only by conditional use permit.
In these cases, the applicant and plan
ning staff must design and demonstrate
site-spec ific noise mitigation . A discretion
ary permit process , including notice and
a public hearing, gives residents a voice ,
while allowing planning staff and commis
sioners to evaluate whether the mitigat ion
is adequate.
By-Right Permit Zone
Beyond about 800 feet in low-noise
environments, a pickleball court may be
permitted by right, provided the applicant
and staff verify that the setback is accurate
and the court complies with any general
development standards. At this distance,
the sound is still audible but significantly
dissipated by natural conditions, and the
risk of significant annoyance is substantially
reduced. Choosing a relatively large distance
such as 800 feet will give the planning staff
greater ability to resolve conflicts by adjusting
the mitigation requirements after play has
begun and the neighbors begin to experi
ence the long-term effects.
De~m.e lBiow Sefbacks Aire
M easure d
For consistency with traditional measures,
the best practice is to specify mea
surement from the nearest fence line or
edge of the paved playing surface of the
court to the property line of the nearest
noise-sensitive use. The use of property
lines for the receiving location recognizes
that residential and institutional properties
are entitled to the quiet enjoyment of their
entire parcel including backyards and out
door spaces .
Use Caution wU:lhl Minimum lLilO>li
Size Standards
Some communities structure their zoning
codes using minimum lot size catego
ries-for example, R-80 or R-120 zoning ,
where the number refers to the minimum
square footage or acreage of the lot. While
this structure may be acceptable for some
uses, owners of large lots often position
courts at the far edge of their property to
maximize separation from their own living
spaces, pushing the court closer to neigh
boring homes. For this reason, minimum
Why Decibe l Limits Fall Short in CUP•
Decibels measure sound pressure level- not human
annoyance. Relying solely on decibel thresholds In CUPs Is Inadequate for plckleball noise, which has unique acoustic traits: a sharp, high frequency "pop" concentrated around 1250 Hertz, repeated randomly hundreds of times per hour, often for many hours a day. This creates a hlghly Intrusive and chaotic soundscape that standard dBA limits fall to capture.
Annoyance Is shaped not just by loudness, but by fre
quency, repetition, duration, time of day, and a person's loss m
as perceived fairness and social conflict-remain unresolved when CUPs focus narrowly on sound pressure alone. More
effective tools Include setbacks, limited hours, quiet paddles, and planning that prevents conflict before It starts.
Average Daily Pop Count=16,038
Thurs. Fri. Sat. Sun. Tues. Wed. Thurs. Fri. Sat. Sun. Mon. (7/4) (7/5) (7/6) (?n) (7/9) (7/10) (7/11) (7/12) (7/13) (7/14) (7/15) lot size standards should not substitute for
setback requirements.
Use Caution w ith Acous iical
Test ing
Incorporating acoustic testing into the
permit review process may appear objec
tive. But in practice, acoustic testing has
been seen to produce uncertain and
inconsistent outcomes. The sound of pick
leball is impulsive and variable, making
measurements or predictions technically
challenging and beyond the capabilities
of municipal staff. Moreover, once testing
is introduced, applicants and opponents
alike may begin consultant shopping
hiring professionals who are known to
Daily number of
pickleba/1 pops
(i.e., number of
noise events) from a
noise study of four
pickleba/1 courts
(Credit: NoiseNet
Operations Pty
Us:!)
Zoning Practice I American Planning Association I November 2025 10 A backyard
basketball court,
converted into a
pick/eba/1 court
(Credit: ucpage/
iStock!Getty
Images Plus)
produce favorable conclusions. This can
erode public trust, escalate disputes, and
burden planning staff and commissions
with technical disputes beyond their
expertise.
For these reasons, cities should favor
clear, distance -based setback standards
rather than subjective decibel thresholds
or testing requirements. Setbacks are pre
dictable, enforceable, and transparent to
all parties.
Additional Limitations for Courts
on Residential Lots
Zoning amendments should incorporate
use-specific limitations that reflect the
nature of the residential property and the
intensity of use.
• Prohibit Rentals of Residential
Courts: Pickleball courts on private
residential lots should not be rented
to third-party users or as a short-term
vacation rental. Rentals transform the
activity from personal recreation into a
commercial-like operation.
• Limit to One Court Per Residential
Lot: No more than one court should
be allowed; multiple courts escalate
the impact.
• Lighting Restrictions: If permitted
at all, lighting should use fully shielded
downlighting and be restricted to peri
ods of active play and end at a specified
time.
• Hours of Operation: Residential
courts should be subject to clear limita
tions on hours of use, especially in the
early morning, late evening, weekends,
and holidays, when neighborhood ambi
ent noise is lower and the potential for
conflict is highest.
• Prohibit Practice Backboards:
Banging the hard ball against a back
board creates even more noise than the
normal impact of paddle against ball.
These limitations reinforce the principle
that residentially located courts must
remain truly accessory in serving an indi
vidual household's use without disrupting
neighboring households' quiet enjoyment
of their property.
Variances and Conditional
Review
It should be expected that applicants may
seek variances from these rules. Variances
provide relief from zoning requirements in
Zoning Practice I American Planning Association I November 2025 11 cases of unnecessary hardship, but they
must be applied carefully in the context of
noise-generating recreational uses.
Applicants may argue that a strict set
back requirement constitutes a hardship
because it effectively prevents building a
pickleball court. A variance to reduce the
required setback would directly conflict
with the ordinance 's intent of preserving
public health, safety, and welfare and
should be denied.
Conversely, some jurisdictions may
have zoning rules that inadvertently pre
vent pickleball courts from being built in
industrial or commercial zones due to
outdated use tables or overly rigid recre
ational use definitions. In such cases, a
use variance may be appropriate. Allowing
courts in areas that are already noisy, non
residential, or buffered from homes aligns
with the intent of minimizing noise impacts
on sensitive receptors.
In many jurisdictions, pickleball-related
noise problems have proven dynamic, not
static. Mitigation measures that initially
appeared sufficient have failed over time
due to increased intensity of use, seasonal
expansion , tournament scheduling, or user
noncompliance. The health impacts on
neighboring residents is cumulative over
time, often supporting additional mitiga
tion. For this reason, zoning ordinances
that authorize pickleball facilities should
include provisions for ongoing oversight
and conditional reconsideration.
Courts facing closure or litigation can
often be rescued by redeploying available
mitigation tools such as quiet equipment
and better management of playing hours.
A provision enabling ongoing supervision
might be:
"In the event that substantiated noise
complaints are received from adjacent
properties, or that the use of the facility
intensifies beyond the levels presented in
the original application, the planning com
mission may schedule a public hearing to
consider modification or revocation of the
conditional use permit. Conditions may
be amended to reduce permitted hours,
require upgraded mitigation, or impose
other restrictions reasonably necessary to
protect the public health, safety, and welfare."
A S11c:ceaa Story: Eisenhower Puk, Denver
8senhower Park's outdoor plckleball courts were shut down In 2023 after persistent complaints from nearby residents.
Standard mitigation approaches failed to reduce the disrup tive impulse sounds at close distances. In response, the city launched a pilot nquiet court" program, reopening the courts under strict conditions: only foam Librarian brand balls are allovved, the courts close at 2 p.m. on Saturdays and remain closed all day Sunday.
While many competitive players dislike the Librarian foam ti>all'• perf9n:naAce, the ~wer Park courts now sen,e a ~~~fl er-fMt pl~ seeking
M ~on Qf
p ayer demand reduces acoustic pressure on adjacent
homes and restores neighborhood compatibility. The Denver program demonstrates how enforceable equipment restric tions and scheduled closures can be combined to resolve conflicts without eliminating access altogether.
Conclusions
Pickleball has become a significant land
use conflict-not because the game itself
is harmful, but because its unique acous
tic signature and rapid expansion have
outpaced zoning codes. The burden of
accommodation should not fall on nearby
residents when the noise impacts are
measurable , foreseeable, and preventable .
Pickleba/1 courts
at Mamie D.
Eisenhower Park
in Denver (Credit:
Google Earth) I
Zoning Practice I American Planning Association I November 2025 12 .,
A Policy Challeng e for the
Gov erning Body
For elected officials of the legislative body,
adopting a clear zoning ordinance is not
just a technical task-it is a test of civic pri
orities. Do the officials place the health and
welfare of its residents first, or do they bend
toward accommodating an optional recre
ational use for a special group of users?
Selecting the minimum no-pickleball
setback is the most important and most
challenging decision . Though tempting to
set a small setback distance of 150 feet
as a few have done, it is the larger mini-
mum setbacks of 250 or 350
or even 500 feet that remove
the most problematic court
locations and give the best
chance of mitigating the noise
and decisively reducing civic
conflict.
Likewise, establishing the
distance at which permits
are freely granted "of right"
without the supervision of a
CUP is a challenge. Although
the noise can travel 1,000
feet, 800 feet can be a good
choice as courts within a
lesser distance can be suc
cessfully mitigated with a
properly administered CUP
and courts over 800 feet have reduced
potential for serious conflict even though
the noise is audible.
An equally critical policy decision is
whether to apply the zoning rules to the
public parks by requiring the parks and
recreation departments to apply for zon
ing approval, just like any other property
owner. When governmental departments
and public parks are exempted from
zoning review, trust erodes, and conflict
escalates. Subjecting public parks to the
same rule of law may be politically difficult
but demonstrates meaningful commitment
to protecting residential quality of life.
Ongoing Management
Challenge for Planning Staff and
Commissions
Once adopted, the ordinance must be
actively implemented and enforced .
Planning staff and zoning commissions
must lead the CUP process: reviewing
proposals, conduct ing hearings, applying
mitigation requirements, and ensuring that
permits remain in compliance over time.
This is a task that requires technical
expertise, policy judgment , and consistent
application-all of which reside in the zon
ing and permitting department. CUPs can
be tailored to require quiet paddles and
balls, sound barriers, and limited hours of
play, but such conditions only work if the
operator can enforce them and the local
staff and officials are prepared to respond
to violations. It is the combination of pro
active zoning and continuing supervision
that provide the most durable path for
ward.
The goal is not to ban pickleball, but
to manage it thoughtfully, just as with all
impactful land uses. Done well, zoning is
not a barrier to recreation-it is the foun
dation for long-term coexistence between
active parks and peaceful homes.
A well-drafted zoning ordinance gives
certainty to recreation departments, devel
opers, club operators, and homeowners
seeking to invest in pickleball facilities.
Variances and ongoing permit review allow
flexibility without undermining its core pur
pose: protecting people in their homes.
About the Author
Charles Leahy is a
retired mechanical
engineer and
attorney who
became involved
in a pickleball
noise dispute
while serving on
the board of a
California homeowners association.
Four tennis courts became 13 pickleball
courts, resulting in a nuisance lawsuit.
Intrigued by the science and politics of
noise, he has presented pickleball noise
research papers at Acoustical Society
of America meetings and given training
on pickleball zoning and permitting for
the International Municipal Lawyers
Association.
Zoning Practice I American Planning Assoc iation I November 2025 13 Additional Resources
American Public Health Association. 2021. Policy Statement 202115: Noise as a Public Health Hazard .
Blomberg Louise. 2016. "Preliminary Results of an Analysis of 491 Community Noise Ordinances." Presented at New
England NOISE-CON-Revolution in Noise Control. Providence, Rhode Island, 13-15 June, 2016.
Leahy, Charles. 2024. "Preliminary Analysis of 79 Pickleball Noise Consultant Reports by 36 Consultants." Proceedings of Meetings on Acoustics, 54 (1): 040009.
NoiseNet Operations US Inc. 2025. "Pickleball Noise Acous tics."
Romito, Kathleen, and Daniel Fink. 2025. "Pickleball Noise:
The Physiological and Psychological Effects on Nearby
Neighbors." Proceedings of Meetings on Acoustics 56(1):
050001.
Romito, Kathleen, and Daniel Fink. 2025. "Pickleball Noise Raises Health Concerns for Neighbors Living Near Courts." Acoustical Society of America 188th Meeting, Lay Language Paper, May 5.
Willis, Lance. 2023. Pickleball Noise Impact Assessment and Abatem ent Planning. Prepared for City of Centennial, Colo rado, Spendiarian & Willis Acoustics & Noise Control LLC, July
11. Wyerman, Barry, and Robert Unitech. 2023. "Pickleball Sound 102-Time History and Spectral Analysis of Pickleball
Sound." NoiseCON 2023, Grand Rapids, Ml, Pages 1-1096:
31-42.
Wyerman, Barry, and Robert Unitech. 2023. "Pickleball Sound 103-Mitigating Pickleball Sound-ls Pickleball Compati
ble with Residential Environments." NoiseCON 2023, Grand Rapids, Ml, Pages 1-1096: 43-53.
Ii
ZONING PRACTICE NOVEMBER 2025 I VOL. 42, NO. 11. Zoning Practice (ISSN 1548-0135) is a monthly publication of the American Planning Association. Joel Albizo, FASAE, CAE, Chief Executive Officer; Petra Hurtado, PHD, Chief Foresight and Knowledge Officer; American Planning Association
Creating Great Communities for All
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