The electron mobility, limited by electron-phonon scattering, is an important optimal performance indicator of emerging 2D materials [1,2]. One of the advantages of two-dimensionality is that it allows very precise control of the carrier density by a gate, which further enables tuning of the electron-phonon interaction [1]. Graphene has an extremely high carrier mobility, partly due to the fortunate planar symmetry making scattering from the highly occupied acoustic flexural phonons (ZA) impossible. Gating a graphene device breaks the horizontal mirror symmetry and reintroduces scattering from ZA vibrations. I examine the effect in several electrode geometries and argue why this scattering mechanism is a limiting factor at moderate to high carrier densities. In addition, I will discuss the temperature dependence of the carrier mobility and show how this depends on the gate configuration employed.