The problem with that point is that they're just not willing to hedge a bet on a program that perpetually fails to meet expectation when playing out of conference against other big boys.
Teams like FSU, ND, Miami, Michigan, Alabama have a history of showing up for the big games. If any of these teams are available with a respectable record in their tough conferences, they are going to get the nod every time.
Until your program builds a rep, you will always be just another Kansas State.
FSU won their conference, and their bowl record is incredible, therefore they get to go to a BCS bowl; people should get over it.