Recent Executive Action on Spending: Potential Impact on Regional Clean Hydrogen Hubs

INSIGHTi

Recent Executive Action on Spending:

Potential Impact on Regional Clean Hydrogen

Hubs

Updated January 8, 2026

The Infrastructure Investment and Jobs Act (IIJA; P.L. 117-58) authorized and funded an $8 billion

program on Regional Clean Hydrogen Hubs (Section 40314 and Division J, Title III, of IIJA)—networks

of hydrogen producers, consumers, and infrastructure in close proximity. The U.S. Department of Energy

(DOE) has committed up to $7 billion to seven consortiums (“selectees”) and obligated a small portion of

that amount. DOE selected a consortium for a Demand-Side Support Initiative valued at up to $1 billion.

Several factors—including the January 20, 2025, Executive Order (E.O.) 14154, “Unleashing American

Energy”; DOE’s reported plans to review all post-presidential election awards; and a January 27, 2025,

Office of Management and Budget (OMB) memorandum pausing obligation and disbursement of federal

financial assistance (later rescinded)—may impact spending on the hubs. Congress may be interested in

monitoring or modifying spending for this program.

Executive Branch Activities

Office of Clean Energy Demonstrations

DOE’s Office of Clean Energy Demonstrations (OCED) manages the funds. The uncertainty regarding

future staffing levels in the executive branch—in response to E.O. 14210, “Implementing the President’s

‘Department of Government Efficiency’ Workforce Optimization Initiative,” and various policy

directions—may impact OCED’s management of the funds.

Awards

DOE has concluded award negotiations for Phase 1, for planning, analysis, and design activities. The

Government Accountability Office (GAO) notes that each hub is “subject to future award negotiations at

the end of each phase.” See Table 1.

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Table 1. Hydrogen Hub Selectees and Phase I Obligations and Outlays

Start of

Period of Performance

Phase 1 Obligation

Outlays

ARCHES H2 LLC

7/17/2024

$30.0 million

$5.629 million

Pacific Northwest Hydrogen

Association

7/19/2024

$27.5 million

$4.857 million

Battelle Memorial Institute

7/24/2024

$29.7 million

$2.189 million

Midwest Alliance For Clean

Hydrogen, LLC

9/1/2024

$22.2 million

$6.052 million

HyVelocity, LLC

11/18/2024

$22.0 million

$1.229 million

Heartland Hydrogen Hub,

LLC

1/17/2025

$20.0 million

$2.389 million

Mid-Atlantic Clean Hydrogen

Hub, Inc.

1/17/2025

$18.8 million

$1.804 million

$170.2 million

$24.149 million

Selectee

Total

Source: CRS analysis of data from USAspending.gov; outlays are as reported as of December 23, 2025.

Notes: Name of selectee is as given in USAspending.gov. ARCHES H2 LLC is more commonly known as the California

Hydrogen Hub. Battelle Memorial Institute is more commonly known as the Appalachian Regional Clean Hydrogen Hub.

HyVelocity, LLC, is more commonly known as the Gulf Coast Hydrogen Hub.

Combined, the consortia, when selected in October 2023, anticipated having operations in 16 states. The

announced, eventual value of each agreement ranges from $750 million to $1.2 billion.

Obligations and Disbursements

Grants and Cooperative Agreements in OCED

According to GAO, a federal agency enters into an obligation when it makes a “definite commitment that

creates a legal liability on the part of the federal government for payment of goods and services ordered or

received.” For competitive grant programs, this definite commitment generally occurs when a grant

agreement or a cooperative agreement is executed. Funds can only be disbursed after they are obligated.

In describing the OCED award cycle, a November 2024 study by GAO noted that once an award is made

to a selectee, “funding is obligated, and payments to reimburse authorized expenses may begin.” Table 1

shows total obligations of $170.2 million, roughly 3% of the appropriated funds (budget authority [BA])

of the $6.4 billion appropriated through FY2025. It is possible that additional obligations for the seven

selectees are proceeding through the pre-award process and have not yet been recorded. Only awards that

have been deemed obligated by the federal agency are recorded against appropriations and reported to

USAspending.gov.

Timing of Obligations

Several factors can affect the timing of obligations. For programmatic reasons, varying amounts of delay

may occur between the date when an agency receives BA and when it obligates that BA. For the hubs,

OCED issued a request for information notice in February 2022, a notice of intent in June 2022, and a

funding opportunity announcement in September 2022, soliciting letters of intent followed by full

applications. President Biden announced seven selectees in October 2023, with the start of the obligated

period of performance shown in Table 1. For the first hubs, 2.5 years separated enactment of BA in IIJA

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and the start of the hubs’ period of performance. A further possibility that could implicate outlays would

be rescissions. A rescission may be initiated and enacted by Congress, such as in an annual appropriations

bill. In FY2020, for example, P.L. 116-94 rescinded $58 million of unobligated funds from DOE’s Energy

Efficiency and Renewable Energy appropriation. In specific circumstances, the President can send a

special message to Congress proposing a rescission under the Impoundment Control Act of 1974 (Title X

of P.L. 93-344).

Potential Impact of E.O. 14154 and OMB Memorandums

Section 7 of E.O. 14154 directs agencies to pause disbursement of funds appropriated in the IIJA, which

includes funds for the hubs. The executive order directs agencies to submit findings to OMB within 90

days of the date of the order. The executive order further directs agencies not to disburse identified funds

until the OMB director and assistant to the President for economic policy have replied.

OMB memorandum M-25-11, “Guidance Regarding Section 7 of the Executive Order Unleashing

American Energy,” discusses the scope of the executive order’s pause on IIJA funds. The OMB

memorandum explains that the pause in disbursements applies only to any IIJA funding supporting

policies at odds with the Trump Administration policies described in Section 2 of E.O. 14154; Section 2

does not explicitly mention hydrogen or the Regional Clean Hydrogen Hubs. Whether or not

disbursements under the Phase I awards are covered by the executive order pause, a federal district court

has since preliminarily enjoined the Trump Administration from enforcing certain “unilateral, nonindividualized directives” to pause federal funds under existing awards.

Members of Congress may choose to debate the relative merits of investing in new technologies, such as

hydrogen, compared to reducing federal spending. Congress may also be interested in how any changes in

spending on the hubs might affect future use of hydrogen fuel and technologies generally or economic

development in regions hosting a hub.

Author Information

Martin C. Offutt

Analyst in Energy Policy

Disclaimer

This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff

to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of

Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of

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