EXHIBIT 99.B.

Opinion and Consent of Lynn S. Mercier

[MASSMUTUAL LETTERHEAD]

April 24, 2000

MML Bay State Life Insurance Company
1295 State Street
Springfield, MA 01111

RE: Post-Effective Amendment No. 5 to Registration Statement No. 033-82060 filed on Form S-6

Ladies and Gentlemen:

This opinion is furnished in connection with the filing of Post-Effective Amendment No. 5 to Registration Statement No. 033-82060 under the Securities Act of 1933 for MML Bay State Life Insurance Company's ("MML Bay State") Flexible Premium Variable Whole Life Insurance Policies (the "Policies"). MML Bay State Variable Life Separate Account I issues the Policies.

As counsel for MML Bay State, I provide legal advice to MML Bay State in connection with the operation of its variable products. In such role I am familiar with the registration statement for the Policies. In so acting, I have made such examination of the law and examined such records and documents as in my judgment are necessary or appropriate to enable me to render the opinion expressed below. I am of the following opinion:

1. MML Bay State is a valid and subsisting corporation, organized under the laws of the State of Missouri
    and operated under the laws of the state of Connecticut.

2. MML Bay State Variable Life Separate Account I is a separate account validly established
    and maintained by MML Bay State in accordance with Connecticut law.

3. All of the prescribed corporate procedures for the issuance of the Policies have been followed, and all
    applicable state laws have been complied with.

I hereby consent to the use of this opinion as an exhibit to this Post-Effective Amendment.