12. CAISO Related Costs

SCE indicates that it incurred approximately $399.3 million in CAISO-related costs during the Record Period, asserting that the majority of these CAISO-related costs were unavoidable. SCE adds that those costs that SCE had limited discretion to control were managed consistent with the objective of minimizing costs to bundled service customers. SCE notes that its request is 16% less than for the 2009 Record Period, but that the cost levels are not directly comparable due to changes in CAISO invoicing. DRA has not challenged SCE's request that the Commission find all CAISO-related costs incurred during the Record Period to be reasonable.

We have reviewed SCE's testimony on CAISO-related costs incurred during the Record Period and conclude they were reasonably incurred.