I just received word from Apple that : a) Apple has given PhoneGap a technical analysis , and PhoneGap does not violate the Terms & Conditions of the App Store. b) Apple will review PhoneGap applications based on their own merits and not on their use of PhoneGap.
What this means:
[ Update:: April 13, 2010 ]
I have received word from Apple that the above is STILL true! If you were concerned by the recent changes to Apple's iPhone developer agreement, this has ZERO impact on PhoneGap!
Apps built with PhoneGap will continue to be reviewed based on their own merits and NOT dismissed/rejected because they use PhoneGap.