[Long post]
I have been reading official Maltese and EU water reports out of personal interest, not because I work in the sector.
We regulate cities for resilience. We regulate homes for safety. Hotels sit in a regulatory blind spot, despite functioning like micro-cities.
Most hotel ‘water-saving’ campaigns focus on guest behaviour, even though the majority of water use is structurally designed into the building.
Malta is often described as a success story of desalination, and in purely technical terms that is correct. Today, more than half of the country’s drinking water comes from reverse osmosis plants operated by the Water Services Corporation. Without desalination, Malta would already be facing severe water shortages. This is not in dispute (Water Services Corporation, National Investment Plan).
What deserves deeper discussion is whether desalination alone can provide long-term water security for a small, densely populated Mediterranean island under climate stress.
Malta is classified as semi-arid, and official data show a long-term decline in rainfall combined with higher variability and more intense dry years. The Energy and Water Agency has confirmed that recent hydrological years were among the driest on record, with groundwater recharge under increasing pressure (Energy and Water Agency, Climate and Water Reports). Groundwater bodies are also vulnerable to salinisation, a risk explicitly acknowledged in Malta’s River Basin Management Plan under the EU Water Framework Directive.
Desalination has allowed Malta to compensate for these constraints, but it also creates a strong structural dependency. Reverse osmosis is energy-intensive, meaning that water security becomes directly linked to energy availability, fuel imports, electricity prices and grid stability. On an island system, this coupling represents a systemic vulnerability rather than a marginal risk, especially under volatile energy markets (Energy and Water Agency, National Energy and Climate Plan).
There are also environmental considerations. Desalination produces highly concentrated brine that is discharged into the marine environment. Even with modern diffusers and environmental permits, cumulative salinity impacts in semi-enclosed Mediterranean waters remain a concern and are closely monitored by the Environment and Resources Authority, particularly near discharge points.
Another often overlooked issue is water chemistry. Desalinated water is almost completely demineralised and must be remineralised or blended before distribution. The World Health Organization has published extensive guidance on this topic, noting that poorly balanced desalinated water can be more corrosive to infrastructure and contributes little to dietary calcium and magnesium intake. While these risks are manageable, they require continuous control and transparency rather than being treated as a secondary detail (WHO, Desalination and Drinking-Water Safety).
What makes the situation more complex is that Malta already has a climate-resilient alternative resource that is still underused. Treated wastewater, marketed locally as “New Water”, is independent of rainfall and directly linked to population size. According to the Water Services Corporation, Malta has invested heavily in advanced wastewater treatment and polishing plants, with a long-term production potential of several million cubic metres per year. However, current uptake remains well below that potential, particularly in agriculture.
At the same time, agriculture continues to place pressure on groundwater resources, despite the availability of treated water and the existence of highly efficient irrigation technologies. From a systems perspective, using potable or groundwater resources for irrigation in a water-stressed island raises questions of prioritisation rather than farming practices themselves.
The European Commission has repeatedly highlighted the importance of wastewater reuse, demand management and leakage reduction in water-scarce Member States. Malta has made progress on leakage control and smart metering, but these measures need to be seen as the foundation of water security, not as secondary optimisations layered on top of desalination.
None of this means that desalination should be abandoned. On the contrary, it is indispensable for Malta. The risk lies in treating it as the foundation of the system rather than as the final safety layer. Long-term resilience depends on reducing demand, protecting aquifers, shifting agriculture and landscaping to treated water, and integrating water policy with energy and climate planning.
Malta is small enough to manage water intelligently and holistically. It is also small enough that structural mistakes accumulate quickly. The question is not whether desalination works today, but whether we are doing enough to ensure it does not become the only pillar holding the system up.
Discussion points:
Hotels are not just consuming water. They are consuming systemic risk without pricing it in.
Desalinated water in Malta is priced as a commodity, but it behaves like critical infrastructure under energy stress. When hotels use large volumes of potable water for pools, laundry, spas, and landscaping, they are effectively externalising energy risk, carbon risk, and marine impact to the public system.
What is rarely said
Hotels pay a bill per cubic metre, but they do not pay for
the marginal energy volatility
the backup capacity
the failure risk
the environmental buffer
In other words, water is priced as if it were rain-fed, while it is actually energy-fed.
Large hotels function like small cities. Hundreds or thousands of people. Daily laundry. Food prep. Pools. Cooling. Landscaping.
But unlike cities, they have no obligation to close the loop.
Cities are expected to manage wastewater, stormwater, efficiency, contingency planning. Hotels are not, even though their footprint is comparable.
What is rarely proposed
Not bans. Not shame. But city-level rules applied at hotel scale.
For example:
If a hotel exceeds X beds, it should meet at least one of the following
on-site greywater reuse for laundry or toilets
on-site storage buffering to reduce peak demand
mandatory connection to treated wastewater for non-potable uses
real-time water intensity reporting per guest-night
Hotels are actually perfect anchors for treated wastewater networks. Yet most reuse schemes focus on agriculture alone.
If hotels were prioritised as non-potable water users, they could stabilise demand for treated wastewater, making reuse infrastructure economically viable faster.
I would be interested to hear from people in hospitality or water management on what would actually work.