How to treat energy storage as a transmission asset?

For energy storage to be part of the transmission solution, storage developers need to work with transmission owners and follow the Regional Transmission Organization (RTO) transmission planning protocols. Federal Energy Regulatory Commission (FERC) Order 841 mostly treats Electric Storage Resource (ESR) as a generation asset. To date, no FERC order lays out a path for treating energy storage as a transmission asset. One of FERC-jurisdictional RTOs - Midcontinent Independent System Operator (MISO) - has sent a "storage as a transmission-only asset" proposal to FERC, which FERC did not reject but did not approve either. This MISO filing begs the question - how to treat energy storage as a transmission project? The industry needs to understand how RTO cost allocation works for new and existing transmission projects. To appreciate cost allocation, stakeholders need to grasp the fundamentals of transmission project categories. Because to put together a business case for storage, modeling is essential. And modeling for reliability and economic projects vary. Getting into the weeds of transmission planning is what it takes to treat storage as a transmission asset.