Absolutely depends on the start up and the type of surface. The main issue with using a heater too soon after fresh plaster is applied is the excess plaster dust that is in suspension in the water. The heater can easily raise the CSI to a level where scaling is possible, especially inside the heater, since water at high temperatures has less ability to prevent calcium from precipitating out of it. With a bicarb startup, the water at its current temperature is already near scaling potential, raising the temperature from the heater will put it significantly over that threshold and likely begin to form scale.
There is nothing magical that happens to plaster after 30 days that makes it OK to use a heater. It is largely based on situation, the present water parameters and how well the plaster dust has been mitigated. I am not advocating using the heater sooner than 30 days but if a pool has been well maintained during the initial startup period, I don't see why there would be any more danger.
This is very similar to not adding salt within the first 30 days. Not doing so is again considered best practice, but there is little harm that is done if the salt is added prior to one month of cure time. Again, I am not advocating this but it does happen very frequently.
Plain plaster finishes are a lot different than the aggregate finishes. The latter are allowed to cure for 24 hours, get acid washed, pressure washed and then filled. Most of the dust has already been removed and pumped out of the pool prior to filling. So long as the remaining dust is taken care of, I don't see why a heater couldn't be used sooner so long as it is known what higher water temperatures will do to the CSI at the current condition of the water.