I suspect Ryan has it correct about the metal versus non-metallic battle. However they allow smurf tubing in Types I, II and III construction, given the consitions of 15 minute finish rating etc.
The State of Michigan has for at least 20 years amended the NEC and allowed NM cable above 3 floors in all types of construction. So the limitations of the '02 and especially the '05 are a step backwards as far as Michigan is concerned. Michigan's record is spotless and the use of NM cable does not cause fires when installed properly. I will concede the fire load issue but if we are in a Type I, II or II construction the chances of fire are lessened. One could argue that NM cable would be less of a fire load risk in I, II and II construction.
