Does riding on a shoulder count as bicycle driving?
No. The shoulder of a road is not designed, constructed, regulated, or maintained for vehicular travel. However, it might be appropriate to ride a bicycle on a shoulder in some circumstances. Such a shoulder should be wide, smooth, clean, unobstructed, and rarely interrupted by driveways and intersections. Bicyclists who are riding on a shoulder should cross driveways and intersections cautiously and should generally merge into the road before crossing an intersection.