5. Conclusion

We find that AB 80 should be interpreted as granting a limited exemption from the suspension of direct access service to participants in the MPP. This exemption authorizes the MPP participants to offer service on an opt-in basis up to their entitlement share of generation power from MPP to retail end-use customers in their jurisdiction. Since the ILL currently represents Cerritos' share of power from MPP on a peak capacity basis, the AB 80 Agreement should be amended to modify the ILL so that it represents Cerritos' share of output from MPP on an energy basis. Cerritos and SCE should also amend the AB 80 Agreement, if necessary, to increase the ILL to reflect Cerritos' procurement obligations under the RPS program.