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There have been and this year CP4 is offroad https://www.transcontinental.cc/tcrno8-cp4
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Yes, there was Assietta in 2015. I didn't ride this edition.
CP3 in 2017 was somewhat unpaved in the Tatras "CP3 parcours was a 7 km long climb with an average 10% gradient, with some sections unpaved, ending at a hotel and mountain lake in the Tatra National Park." from Ride Far but I don't actually remember the climb at all myself.
2018 Karkonosze Pass was claimed to be unpaved but IIRC it was just a shitty mountain road, ie. still more pavement than not. Bjelašnica was definitely unpaved and unrideable in sections. It was dust and rock and a proper bastard. Really should've had walking shoes for this as it trashed my good shoes.
2019: CP2 had 80 km of mostly dirt/gravel roads and a climb up to the peak of Besna Kobila at over 1,900 m elevation in Serbia. Very steep and too rough to ride parts. Most of the top 2k was walked
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MisterTomTom
hippy
@Zerostar
Right. Hadn’t zoomed in enough to realise that’s where it was. Is my memory playing tricks with me in making me think there have been off road segments at checkpoints in previous editions?