Plenum wiring where in the code also does it have to be plenum wire in return air cha

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That sounds like an AHJ call. On the flip side Los Angeles County does not enforce any part of 725 for residential - at least in 2008. You can run any unlisted and unmarked class 2 wire in wall. Article 725 is all about smoke and toxic fumes. It's really not an electrical hazard but more of a fire and smoke issue. I guess in a residence there is simply not enough wire in the walls to present a hazard considering all the other toxic plastics like furniture foam in place.
 
If it is an actual duct it is a 300.22(B) space.

If it is a stud or joist space used as a plenum, it is a 300.22(C) space, with an exception to permit non-plenum wiring methods to pass though such spaces perpendicular to the long dimension of the stud or joist space.
 
One of my students commented that panning ducts to use as a RA is not often done, due to air infiltration.
HVAC ducting now is all sealed to prevent air leaks
 
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