> The plenum type of cable has a "less toxic" smoke from its insulation

Plenum cable uses Teflon insulation, so NO SMOKE IS PRODUCED WHEN
BURNED.  I've tested this myself with a propane torch (outdoors).

The electrical Code may vary between commercial and residential
installations, but plenum cable SHOULD be used in all plenums, including
wiring trays, not just air-handling ducts.  Suppose a cable get
energized with 110/240 volts!  People do the most unlikely things, so
you should consider fire caused by short circuit, not just hot pipes.  

I think Chad got it right when he said it's not required if sealed
behind sheet rock.

PS
If you don't have to use Teflon, you may not want to: the twisted pairs
are "stuck" together making termination with RJ-48 (8-position
connectors) difficult.  You'll need to use a knife or razor blade to
separate the pairs.  If you're using punch-down style termination boxes,
then there should be no issue.