In Love v. City of Philadelphia, 518 Pa. 370, 543 A.2d 531 (1988), our Supreme Court addressed what was meant by "operation" as used in 42 Pa. C.S. 8522(b)(1). That case involved an elderly woman who fell while using a portable step to assist passengers when exiting a city-owned van. Holding that the negligent placement of the portable step did not fall within the exception, our Supreme Court held that for a vehicle to be in operation, it had to be moving. It explained that: "To operate something means to actually put it in motion. Merely preparing to operate a vehicle, or acts taken at the cessation of operating a vehicle are not the same as actually operating that vehicle.. Getting into or alighting from a vehicle are merely acts ancillary to the actual operation of that vehicle." 518 Pa. at 375, 543 A.2d at 533. The Supreme Court interpreted the term 'operation' of a motor vehicle. Love involved a transportation service administered by the city of Philadelphia that transported senior citizens between an adult center and their homes. Catherine Love, who was seventy-three years old and visually impaired, utilized the assistance of the vehicle's driver in boarding and disembarking from the vehicle by means of a portable step that the driver would place at the door of the vehicle in order to facilitate Love's step onto the curb in front of her home. Love fell while alighting from the van and was seriously injured. Love claimed that her injuries were caused by the driver's negligence and that the city was not immune from suit because of the motor vehicle exception to the Tort Claims Act. The Supreme Court noted that neither the Tort Claims Act nor the general definition section of the consolidated statutes defined the word 'operation'. The Supreme Court determined, based upon the legislature's intent to shield local agencies from tort liability, that "we are constrained to strictly construe the crucial term, i.e., 'operation'." Id. at 532. In determining the meaning of 'operation' within the Tort Claims Act, the Supreme Court found that "to operate something means to actually put it in motion," and further stated that its interpretation of the term was "the common and approved usage of the word 'operation.'" Id. at 533. Thus, the Supreme Court declined to apply the motor vehicle exception, as the van in which Love was exiting was not moving at the time of her fall and, thus, was not in operation within the meaning of the Tort Claims Act. Id.