In a couple of years players will want more HD quality cinematic content in games, and there is a limit for how much HD quality content can fit on a DVD. This is why some developers who are known for their heavy emphasis on animation and environmental content might want to concentrate on PS3. A good example is the MGS4, and we will be seeing more and more of massive game projects exclusive on PS3 as the demand for distribution capacity grows with game development ambitions.
How about the external BR-players for 360 then? While in the past some game projects have been succesfull in requiring hardware add-ons to be playable, I think that in the current market situation this (requiring the purchase of additional hardware to play a certain game) would only make 360 appear even more like a variety of PC and not a gaming console.
So, aware of the Rockstar past projects and ambitions, I don't see it as impossible that they might consider some projects as PS3 exclusives, even if the GTA4 will sell more on the 360.
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