One challenge in crafting responses to the notice of intent (NOI) is that it lacks clarity on two important aspects. The first is the intended recipients of the subsidies. Would the subsidies be directed, as our reading suggests, only to offtakers within hydrogen hubs, or even a subset of them “chosen competitively” (as stated in the NOI)? Or could the subsidies be used to develop H2 demand outside of the hubs? It is also unclear from the NOI the specific problem that the Department of Energy (DOE) is seeking to address. Do the hub applications not reflect reasonable certainty about offtake demand now and/or after the money runs out? Are H2 prices expected to be too high? Are risks greater than offtakers can tolerate?