Cause not developing for Android cause of non-Market accessing devices and the fact that some 10% of devices are below 2.1 is like not developing for Apple cause a certain number of people never update their phones and the looming app rejection. It is a real problem, but it is really kinda something you have to handwave away if you are going to be realistic about doing business on a platform.
Who said it was a reason to not develop? No-one's making that argument.
I'm arguing in favor of being realistic.
And part of that includes admitting that there are causes for concern. And because of them, you might invest efforts into an app only to find yourself in 2012 facing the most-popular android devices shipping with only a carrier- or manufacturer-specific markets installed by default, each with their own hoops.
And, no, even that situation won't be a blanket argument against developing for Android.
But it also won't mean fragmentation was something that is a non-issue so long as you have a good coder.