1. Height
Examples

2. Context 1000m/100 km is the ACEA proposed limit for accumulated height
Following examples are from moderately high areas of Europe (Alps, Pyrenees, etc. not evaluated).
All trips are covering at least a medium sized city, many are in quite densely populated areas
Google maps bike routes have been used, only available in selected EU states (Germany, France, Belgium, UK…)
Trips are of course not RDE compliant, but serve as indication (~1/3 urban, ~100 km in length).

3. As RDE trips have to start with an urban part, the starting location is always in the city.
Most of trips we made randomly, without any prior knowledge of the area (not picking the worst uphill parts).
Google cycling paths are always "choosing" the least demanding trip for the bike driver (logical), not the shortest one.
Inside the city, only streets for bicycles can be used – for instance in Brussels, this means all steep underpasses and tunnels are avoided.
Resolution is probably low, with more exact measurements the height would have been bigger.

4. EU cities and routes 1256 m/100 km
Sheffield – Huddersfield. not in the most hilly parts of the country (NOT Wales or Scotland).
Significantly over the limit.

5. Manchester -> NO2 exceedance
993 m/100 km
Manchester -> NO2 exceedance
Manchester – Sheffield UK, not in the most hilly parts of the country (NOT Wales or Scotland).
Very close to the limit.

6. Newcastle -> NO2 exceedance
906 m/100 km
Newcastle -> NO2 exceedance
Newcastle – Carlisle. Under the limit, but on the optimal route between these cities.

7. Luxembourg -> NO2 exceedance
1108 m/100 km
Luxembourg -> NO2 exceedance
Variations after the SAME Luxembourg city trip – this one is towards Germany.

8. Luxembourg -> NO2 exceedance
957 m/100 km
Luxembourg -> NO2 exceedance
Variations after the SAME Luxembourg city trip – this one is towards Germany, but further to the north.

9. Luxembourg -> NO2 exceedance
969 m/100 km
Luxembourg -> NO2 exceedance
Variations after the SAME Luxembourg city trip – this one is towards France.

10. Luxembourg -> NO2 exceedance
953 m/100 km
Luxembourg -> NO2 exceedance
Variations after the SAME Luxembourg city trip – this one is towards Belgium.

11. Luxembourg -> NO2 exceedance
1146 m/100 km
Luxembourg -> NO2 exceedance
Variations after the SAME Luxembourg city trip – this one is inside Luxembourg, over the limit!!!
All Luxembourg trips show how difficult is to make a valid trip with a border value at 1000m.

12. 1286 m/100 km
Liege – Bastogne, Belgium. This shows that significant exceedances of the limit can be found even in
Belgium.

13. 1205 m/100 km
Liege – SW, Belgium. This shows that significant exceedances of the limit can be found even in
Belgium.

14. Mainz, Wiesbaden, Koblenz -> all with NO2 exceedance
1094 m/100 km
Mainz, Wiesbaden, Koblenz -> all with NO2 exceedance
Mainz Wiesbaden Koblenz. Very populated part of Germany, over the limit!

15. Kassel -> NO2 exceedance
1075 m/100 km
Kassel -> NO2 exceedance
Kassel to the West. Over the limit! A lot added in the city (river valley)

16. Freiburg -> NO2 exceedance
1333 m/100 km
Freiburg -> NO2 exceedance
Freiburg to east. Demonstrates that only valid trips from Freiburg can be made along the Rhine,
nearly every one to the east is over the limit.

17. Lyon and St. Etienne -> NO2 exceedance
1068 m/100 km
Lyon – St. Etienne. Higher than the limit! Similar routes possible all over the South-Central France.

18. 824 m/100 km
Saarbrucken - Luxembourg. Only the optimal path, following the river is under the limit,
because a lot of height is already added in the city.

19. 1426 m/100 km
SAME city trip in Saarbrucken, this time a different route to the countryside – significantly higher
than the limit.
8 German states show problems with the boundary at 1000m/100 km (NOT including the Alpine parts!).

20. 1029 m/100 km
Jena - Zwickau. Another over the limit, this time in Thuringia.

21. Brussels city routes Brussels -> NO2 exceedance 250 m GAINED
Following examples show significant differences between multiple routes in a city. Brussels is definitively
Not a mountainous city, but a lot of accumulated height can be gained.

22. 184 m GAINED

23. 156 m GAINED

24. 56 m GAINED
North – South, along the Canal – small addition to the accumulated height.

25. 185 m GAINED
East - West, perpendicular to the Canal – addition to the accumulated height is more
than three times bigger!

26. Mediterranean cities and routes
1093 m/100 km
Marseille -> NO2 exceedance
Marseille + surroundings, No1

27. Marseille -> NO2 exceedance
1189 m/100 km
Marseille -> NO2 exceedance
Marseille + surroundings, No 2

28. Marseille -> NO2 exceedance
1041 m/100 km
Marseille -> NO2 exceedance
Marseille - Toulon

29. Marseille -> NO2 exceedance
1187 m/100 km
Marseille -> NO2 exceedance
Marseille – Toulon, route 2

30. Marseille -> NO2 exceedance
800 m/100 km
Marseille -> NO2 exceedance
Under the limit only because of
a long flat stretch!!!

31. Marseille -> NO2 exceedance
1057 m/100 km
Marseille -> NO2 exceedance
Over the limit, even with a long coastal part!!!

32. 1860 m/100 km
Seriously higher than the limit!!! Even though it is a coastal route (Menton -> Cannes). This is
representative for a big part of Mediterranean. See Liguria, just over border (for example Genoa)

33. 1340 m/100 km
Ajaccio, Corsica, higher than the limit! This a relatively gentle Corsican route – not going significantly to the interior.

34. 1464 m/100 km
Bastia,Corsica, significantly higher than the limit! Only part of the route going to the interior. Quite representative for Sardinia, Sicily, Cyprus, Baleares, Canaries, Crete…

35. GPS visualizer – different software, questionable resolution, for indication of other MS
Genoa city trip + trip to La Spezia. Profile on the right is just an indication (values are very high)

36. GPS visualizer – different software, questionable resolution, for indication of other MS
Bilbao city trip + trip to San Sebastian. Profile on the right is just an indication (values are very high)

37. Some ideas/conclusions:
The parameter itself seems relatively reasonable, but the limit is too low.
There are numerous examples from these countries which are very close to the proposed limit or are substantially over it.
A bit more hilly city can add m of altitude gain BEFORE going to the countryside.
See multiple Brussels examples.
Serious issues with coastal cities, especially at the Mediterranean.
Such cities go quite steep, and a normal trip inside the city (couple of times going from the harbour to the inner-city ) adds a lot of height

38. Best examples are from Southern France and Corsica.
Even quite coastal trips add a lot of height. Practically any trip going from such a city to interior would be invalid.
It can be assumed that it is similar in Spain, Portugal, Italy, Slovenia, Croatia, Greece… These countries cannot be shown in Google Maps cycle paths.
Similarly, cities with a river making a deeper valley are also problematic (a lot of height added in the urban part).