My book says from the "travelled" portion of the road. If the road is paved, the shoulder isn't the travelled portion.
The shoulder of a gravelled road isn't either.
I don't understand why in southern Ontario you can't shoot from the same spot. As long as you are not shooting across or along, whats it matter if you cross the ditch and go 30 feet into the bush. Heck, half the stuff I shoot, if I did that I would be shooting back towards the road.