HomeMy WebLinkAboutOrd 15-20 Urgency Ordinance Establishing a Temporary Cap on Commission Charges by Third-Party Food Delivery ServicesOrd No. 15-20, Item 4.13, Adopted 09/15/2020 Page 1 of 5
URGENCY ORDINANCE NO. 15 - 20
AN URGENCY ORDINANCE OF THE CITY OF DUBLIN
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AN URGENCY ORDINANCE OF THE CITY OF DUBLIN ESTABLISHING A TEMPORARY
CAP ON COMMISSION CHARGES BY THIRD-PARTY FOOD DELIVERY SERVICES ON
DUBLIN RESTAURANTS DURING THE COVID-19 PANDEMIC
WHEREAS, on March 1, 2020, the Alameda County Health Officer declared a public health
emergency; and
WHEREAS, on March 4, 2020, California Governor Gavin Newsom issued a State of
Emergency Proclamation for the State of California; and
WHEREAS, on March 16, 2020, the Alameda County Health Officer issued an order
directing all individuals living in the County to shelter at their place of residence, subject to certain
exceptions; and
WHEREAS, on March 16, 2020, the Dublin City Manager, acting as the Director of
Emergency Services, proclaimed the existence of a local emergency within the City of Dublin
pursuant to Dublin Municipal Code Chapter 2.44.060(A); and
WHEREAS, on March 18, 2020, the City Council at a special City Council meeting, ratified
and extended the proclamation of existence of a local emergency; and
WHEREAS, on March 19, 2020, the Governor of California issued a stay-at-home order to
protection the health and well-being of all Californians and slow the spread of COVID-19; and
WHEREAS, the Alameda County Health Officer issued subsequent revised Shelter In
Place Orders, including on March 31, 2020, April 29, 2020, May 18, 2020, and June 5, 2020,
which included extending restrictions on activities and requiring individuals to shelter at home,
and allowing for certain specified activities; and
WHEREAS, on April 10, 2020, the Director of Emergency Services fully activated the
Emergency Operations Center virtually at Level 3 (Response Level) to coordinate the City’s
response to the COVID-19 pandemic; and
WHEREAS, on May 5, 2020, the City Council reaffirmed and revised the proclamation of
existence of a local emergency; and
WHEREAS, on June 18, 2020 the Alameda County Health Officer revised the June 5, 2020
Order, effective June 19, 2020, to allow outdoor restaurant dining as well as other specified
activities, but not allowing for any indoor dining; and
WHEREAS, on July 13, 2020, the State Public Health Order issued an Order closing all
indoor restaurant dining statewide, among other indoor operations; and
WHEREAS, as a result of the public health emergency and the orders issued by health
authorities, restaurants in the City of Dublin have been limited to takeout and delivery offerings
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(plus limited outdoor dining if available but often with reduced capacity) which has led to a sudden
and severe income loss and financial strain for Dublin’s restaurants, particularly those who
operated on thin margins before the pandemic and those who did not have robust takeout and
delivery infrastructure or outdoor seating capacity; and
WHEREAS, many consumers use third-party applications and websites to place orders
with restaurants for delivery and takeout and these applications and websites typically charge the
restaurants between 10 and 30 percent of the purchase price of the order as a commission; and
WHEREAS, restaurants have limited bargaining power to negotiate lower fees with third-
party platforms, given the high market saturation of third-party platforms and the dire financial
straits restaurants are facing in this COVID-19 emergency; and
WHEREAS, state anti-gouging laws and State of California Executive Order N-44-20
provide protections against profiteering and unscrupulous business practices but do not provide
any protections in the market for food delivery services; and
WHEREAS, if retail food providers raise their costs or close as a result of high fees from
third-party delivery services, their workers will lose employment, thereby affecting their ability to
provide for their families, and the community will lose access to essential food services for its
residents; and
WHEREAS, continuity of operations among the City’s restaurants is critical for the delivery
of essential food services to the residents of Dublin and to sustain these sources of employment
and neighborhood vitality within the City; and
WHEREAS, several Bay Area jurisdictions, including San Francisco, Oakland, Berkeley,
Fremont, San Leandro, and Livermore have experienced significant increases in delivery fees
from third-party delivery services that also operate in Dublin and have recently enacted similar
measures to cap the fees they may charge at 15 percent; and
WHEREAS, the City of Dublin has heard from local businesses who attest to increasing
delivery fees from third-party delivery services looking to leverage their position during the COVID-
19 emergency; and
WHEREAS, capping delivery service fees at 15 percent per order, will achieve the public
purpose of ensuring the continued operation of local restaurants and third-party platforms during
the period of emergency; the 15 percent cap is based on the findings and experience of other
California cities and cities nationwide that have already adopted 15% fee ceilings or similar caps
as reasonable emergency regulations; and
WHEREAS, the California Constitution, Article XI, Section 7, provides cities with the
authority to enact ordinances to protect the health, safety, and general welfare of their citizens;
and
WHEREAS, California Government Code Section 36937 authorizes the City Council to
introduce and adopt an ordinance it declares to be necessary as an emergency measure to
preserve the public peace, health and safety at one and the same meeting if passed by at least a
four-fifths affirmative vote; and
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WHEREAS, in light of the economic impacts of the public health emergency on local
restaurants and the necessity to preserve access to essential services and protect public health
and safety in Dublin, the City Council finds and determines there is an immediate need to preserve
public health, safety and welfare by enacting an ordinance to cap the per-order fee third-party
applications and websites can charge restaurants during the term of this emergency; and
WHEREAS, it is in the public interest to take action to ensure the delivery of essential food
services to residents of Dublin and to maximize restaurant revenue from the takeout and delivery
orders that, with the exception of limited dining operations, are currently one of the primary
sources of revenue for these businesses to enable restaurants to survive this crisis and remain
as sources of employment and neighborhood vitality in the City; and
WHEREAS, as restaurants return to modified, lower capacity restaurant service, it is
unclear how restaurants will fare, as restaurants must create new, physically distanced dining
areas and implement increased training and sanitation measures; and
WHEREAS, it is unclear how quickly restaurant patrons will return to restaurant dining and
restaurants may continue to see a significant loss of revenue for an ongoing period of time; and
WHEREAS, this Urgency Ordinance is temporary in nature and only intended to promote
stability and safe and healthy operations within the restaurant and food markets in the City during
the COVID-19 pandemic outbreak, and to prevent avoidable business closures thereby serving
the public peace, health, safety, and public welfare and ensuring jobs and economic vitality within
the City, while also preventing further spread of the virus; and
WHEREAS, a Staff Report was submitted to the Dublin City Council recommending
approval of the Urgency Ordinance; and
WHEREAS, the City Council did hear and consider all said reports, recommendations and
testimony herein above set forth and used its independent judgment to evaluate the Urgency
Ordinance.
NOW, THEREFORE, the City Council of the City of Dublin does hereby ordain as follows:
Section 1. Recitals. The recitals above are true and correct and incorporated herein by
reference.
Section 2. Urgency Findings and Declaration. The City Council finds and declares that there
is a current and immediate threat to public health, safety and/or welfare, and this Urgency
Ordinance must be adopted as an urgency matter necessary for the immediate preservation of
the public peace, health, and safety. This finding is based upon the facts set forth and referenced
herein, including the Recitals above, the staff report, any oral and written testimony at the
September 15, 2020 City Council meeting, and the entirety of the record before the City Council.
Based on said findings, facts and circumstances, the City Council finds that this Urgency
Ordinance should be adopted as an urgency measure for the immediate preservation of the public
peace, health and safety, and that this Urgency Ordinance is an emergency response measure
aimed at ensuring the vitality and return of the restaurant industry after closure and limited
operations, and should go into effect immediately as described below.
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Ord No. 15-20, Item 4.13, Adopted 09/15/2020 Page 4 of 5
Section 3. Food Service Delivery Commissions Cap and Prohibitions.
1. It shall be unlawful for a third party food delivery service to charge a covered establishment
a fee or commission per online order for the use of its services that totals more than fifteen
percent (15%) of the purchase price of such online order.
2. A third party food delivery service shall offer customers the option to, as a part of an online
order for delivery, authorize a tip or gratuity to be paid to food delivery service workers and
any covered establishment from which the customer places an order through the third-
party food delivery service. It shall be unlawful for a third-party food delivery service to
reduce the compensation, including any tip or gratuity, paid to any food delivery service
worker, or to reduce any tip or gratuity authorized by a customer to be paid to any covered
establishment as a result of the prohibitions stated in this ordinance.
3. For purposes of this ordinance, the following definitions apply:
a. "Covered establishment" means a restaurant, eating or drinking establishment, or
similar food facility that offers, in a single commercial transaction over the internet,
whether directly or through a third party food delivery service, the sale and same-
day delivery of food to customers from one or more retail locations within the City.
b. "Online order" means an order placed by a customer through a platform provided
by a third party food delivery service for delivery or pickup within the City.
c. "Purchase price" means the menu price of an online order. Such term therefore
excludes taxes, gratuities and any other fees that may make up the total cost to the
customer of an online order.
d. "Third party food delivery service" means any individual, firm, association,
corporation or entity through any website, mobile application or other internet
service that offers or arranges for the sale of food and beverages prepared by, and
the same-day delivery or same-day pickup of food and beverages from a restaurant,
eating or drinking establishment, or similar food facility located within the City.
4. A covered establishment or food delivery service worker claiming a violation of this
ordinance shall first provide written notice to the third party food delivery service of the
specific section of this ordinance which is alleged to have been violated and the facts to
support the alleged violation. The third party food delivery service shall have seven (7)
calendar days from the date of receipt of the written notice to cure any alleged violation
including but not limited to providing a refund of any charges exceeding the caps imposed
herein.
5. If, after written notice is provided pursuant to section 4 above and the third party food
delivery service fails to cure the alleged violation, including failing to provide a refund or
continuing to charge fees in violation of this ordinance, the person or entity claiming a
violation of this ordinance may bring a civil action seeking damages and injunctive relief.
The prevailing party in any such action shall be entitled to an award of reasonable
attorney’s fees.
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Ord No. 15-20, Item 4.13, Adopted 09/15/2020 Page 5 of 5
6. This ordinance is not intended to, and does not, create any rights or benefits, substantive
or procedural, enforceable at law or in equity, against the City of Dublin, its elected and
appointed officials, its departments, officers, or employees.
Section 4. Severability. The provisions of this Ordinance are severable and if any provision,
clause, sentence, word or part thereof is held illegal, invalid, unconstitutional, or inapplicable to
any person or circumstances, such illegality, invalidity, unconstitutionality, or inapplicability shall
not affect or impair any of the remaining provisions, clauses, sentences, sections, words or parts
thereof of the ordinance or their applicability to other persons or circumstances.
Section 5. Effective Date. Following adoption by at least a four-fifths vote of the City Council,
this Ordinance shall take effect and be enforced immediately, and shall expire one (1) year from
the effective date, or upon the termination of the local state of emergency, whichever occurs first;
or as otherwise terminated, modified or extended by the Dublin City Council.
Section 6. Posting. The City Clerk of the City of Dublin shall cause this Ordinance to be
published or posted in the manner required by law.
PASSED, APPROVED AND ADOPTED this 15th day of September, 2020 by the following
vote:
AYES: Councilmembers Goel, Hernandez, Josey, Kumagai and Mayor Haubert
NOES:
ABSENT:
ABSTAIN:
_____________________________
Mayor
ATTEST:
_______________________________
City Clerk
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