Why can't we access the h1 element using the document.getElementById() instruction?

Because it doesn't have an ID setBecause we can only access one element a timeBecause h1 is not a valid element name<html>
<body>
<h1>The New York Times</h1>
<h2 id="basic">Basic subscription</h2>
<h2 id="device">
Unlimited reading on any device
</h2>
<script>
</script>
</body>
</html>]]>

We can't access the h1 element because it doesn't have an ID set.