Controlling the Gray Zone

One important industry standard – often articulated formally in driver training manuals – is to either pull the bus or coach within one foot of the curb, or position it no less than three or four feet away. A parallel caveat requires the vehicle to be positioned parallel to the curb. The purpose of these requirements is to keep passengers – particularly those alighting – from having to step into the “gray zone” between the bottom step and the curb.

If a two-door bus or coach is not pulled parallel to the curb (assuming there is a curb), yet the front door is close to it, the rear door almost always lies in the gray zone. The exception is when drivers “nose in” so sharply that the rear door lies more than three or four feet away from the curb. But even when there is no rear door, nosing in creates a trapezoidal area outside the front stepwell – instead of the rectangular sliver of space that most passengers expect.

These requirements are not pedantic details:

• Stopping on the near-side of the intersection when caught by a red traffic signal, a transit driver angled his bus toward the curb and ordered the passengers waiting to alight to “get off here, because I’m not going to stop on the other side” – the far side of the intersection where the designated stop lay. The designated stop contained a large, flat, dry, level bus pad and shelter. On the near-side corner, the curbing was broken and splintered. The second passenger off the bus did not see how far the bottom step lay from the curb because the first passenger exiting blocked her view. Only when she began stepping off did she notice the curb lying roughly three feet away. Too late to pull back, she stretched out to reach the curb – only to find it chipped and cracked. Trying to land on this unstable surface, the passenger fell, breaking her leg and hip, and leading to a costly law suit.


• Pulling into a bus depot configured in a saw-tooth pattern, transit drivers could pull their buses close to and parallel to the curb with practically no effort. So most drivers did. One who did not nosed in, forcing a disabled, cane-using passenger to step out onto the inevitable trapezoid. His cane landed on the higher curb surface while his right foot, just behind it, dropped 14 inches to the pavement – surprising the passenger who, after almost regaining his balance, fell down and broke his hip.


• A paratransit driver pulled up parallel and close to the curb in front of an elderly passenger’s house, and then backed up toward, and angled into, the front section of her driveway. Assisted off the van by the driver standing at the bottom of the stepwell, the passenger’s left foot stepped down onto a sloping section of the edge of the driveway. With one hand under the passenger’s elbow, and the other holding her hand, the driver started to help lift her off the bottom step as she stepped forward. When her left leg buckled, the driver’s grip-and-lift effectively flipped the passenger off the stepwell.


• Late one moonless night, pulling parallel and close to the curb at a church where most passengers had parked their cars, a motorcoach driver aligned his front door with a segment of curbing that sloped downward, longitudinally, on both sides of a driveway. Expecting to land on a flat surface, an alighting passenger’s first foot off stepped onto the slope, and the rest of him tumbled off the coach into the gutter. Here, the landing area was at least a rectangle. But the curbing edge of it sloped down.

Expectation and Realization

Improperly positioning a bus or coach is not a triviality. Passenger expectations are compounded by the fact that all but the first passenger alighting generally do not even see where the curb edge and surface are until at least one of their feet has left the bottom step. Equally or more problematic are the expectations modern passengers have that, if the bus is not pulled close to and parallel to the curb, at least the front stepwell will be “kneeled.” When the driver discharges them into the gray zone and also fails to kneel the bus or coach, these expectations often force passengers to regain their footing while midway between the stepwell and the ground surface – already off balance as a starting point. Particularly when the passengers are elderly, as 60% of motorcoach passengers are, a broken hip can mean a long, painful slide into death -- and huge “damage awards” when the inevitable law suit unfolds.

Some drivers fail to properly position their buses or coaches because they lack the skill. But demonstrating that they have the skill and were well-trained can make the outcome of a lawsuit even worse: If the driver possessed the skill to properly pull in, then his or her failure to do so for the victim may appear reckless and deliberate – what attorneys refer to as “reckless disregard.” In many states, a finding of reckless disregard can trigger punitive damages.

Color and Conspicuity

Where the roadway is composed of concrete rather than asphalt, the distinction between the curb surface and roadway can be difficult to see – particularly when the observer is in motion and about to step off the bus with his or her “trail leg.” When the ground is covered with snow, this distinction is often invisible.

The problems that positioning the bus in the “gray zone” creates are obviously more dangerous when a passenger is visually-impaired. So in the predictable lawsuit, it does not play well to the jury when the individual accused of being blind is the driver.