I suppose the AHJ makes the rules but article 100 says wet locations are "... unprotected locations exposed to weather". In 2008 they also removed the confusion about above grade wet location raceways
I can think of one place near here that interpreted NM outside as ok in a conduit sleeve. Seems that changed the "unprotected" into "protected" and made everything OK. Sure that wasn't the intent but I can see how they came up with that.