And that is high. They don't exist. Look at 2007 and 2008. In 2007, 0 teams went undefeated. In 2008, only Utah was undefeated. Who would pick a 12-0 BYU team over:

2007: Ohio St (11-1), LSU (10-2), Va Tech (11-2), Oklahoma (11-2), Georgia (10-2), USC (10-2)
2008: Oklahoma (12-1), Florida (12-1), Texas (11-1), Alabama (12-1), USC (11-1), Penn St (11-1)

Those teams have better SOS, better conferences, conference championships, and here is the most important part: contractual obligations (which BYU, as an independent, doesn't have).

In 2007, do you take a 12-0 BYU, who only played 3 BCS teams, and out of those 4 teams, only one went to a bowl game (Texas) and the other two may very well only have 2 wins between themselves (Cal and Virginia), or conference champion, Ohio St, LSU, Va Tech, Oklahoma or USC? Or, in 2008, conference champion Oklahoma, Florida, USC, Penn St.

I would put money down, no undefeated Independent BYU team will ever play in the playoff.