Recommendations – National Water Management Plan

By the Malta Business Bureau’s EU LIFE+ Investing in Water Project

March 2014

1

This document presents recommendations for consideration as part of the public consultation on the formation of

a National Water Management Plan by the Ministry for Energy and Health. They are being submitted based on

experience and findings of the MBB's EU LIFE+ Investing in Water Project – LIF10 INF/MT/000091.

The project focused on the best practice dissemination of water saving results for industry, amongst businesses

and hotels. It was managed by the Malta Business Bureau with support from partners the Malta Chamber of

Commerce Enterprise and Industry and the Malta Hotels and Restaurants Association, received 50% co-

financing from the LIFE financial instrument of the European Community, with further financial support from

the Ministry for Sustainable Development, the Environment and Climate Change, the Ministry for Energy and

Health, Easy-Dry, and sponsorships from APS Bank Ltd, Island Hotels Group, and MSV LIFE.

2

Contents

Section1 - Executive Summary 3

Section 2 – Background to the problem 4

Section3 - Measure specific recommendations 6

Affecting demand 6

Supply of non-conventional water resources 7

Measures - efficient consumption 8

Measures – harvesting rainwater 9

Measures - treating waste-water 11

Section 4 – Supporting Documentation 13

Greening the Economy Recommendations 13

1. Background 14

2. Description 14

2.1 A grey-water treatment policy for new hotels/hotels undergoing infrastructural renovation 15

2.2 Awareness raising for hotel operators about the benefits of grey-water treatment 16

2.3 Grants – funding grey-water treatment 16

2.4 Suggested timeline 18

3. Desired outcome 18

4. Benefits to increased grey-water adoption 19

4.1 Generation of Green Jobs 19

4.2 Water and energy savings 19

3

Section1 - Executive Summary

These recommendations are being presented to the Ministry for Energy and the Conservation of Water

as part of the public consultation process leading to the development of a National Water Management

Plan.

Malta suffers from severe water scarcity, with not enough naturally occurring freshwater to meet

demand. Furthermore, the quality of Malta’s naturally occurring freshwater is deteriorating and is

already considered inadequate to meet potable water demand due to nitrate pollution by various

sources, and over-extraction. Climate change is expected to result in changes to rainfall patterns,

leading to increased high intensity events, increasing flooding and decreased groundwater recharge.

The technology used to generate freshwater is energy intensive, incurring costs in the production of this

water.

The above highlight the fact that Malta needs to ensure that the limited water it does have, is used

efficiently, and that all sustainable water sources are used to their full advantage. The Project partners

therefore advocate a demand management strategy coupled with awareness raising of efficiency

measures, and a supply augmentation strategy facilitating and promoting the use of non-conventional

water resources.

Specifically, the demand management strategy should facilitate and prioritize the use of efficient

technology. This could be done through the establishment and promotion of an Eco-Label for water

consuming appliances. Supply augmentation should take into consideration existing best practice in the

in-house rainwater harvesting and re-use, grey-water treatment, black-water (sewage) treatment, and

industry specific waste-water treatment. At the same time, externally sourced non-conventional water

resources, such as rainwater or municipally treated sewage effluent, should also be optimised for

consumption by sectors in which demand for 2nd

class water already exists.

The measures proposed in this document could be financed through various sources, including existing

funds allocated to ministries/departments/authorities, EU funds including structural funds and direct

funds (such as LIFE), financial engineering instruments such as JEREMIE, and public-private

partnerships.

4

Section 2 – Background to the problem

Water Scarcity in Malta

Malta has only an estimated 25,000,000 m3 of naturally occurring freshwater sustainably available on

an annual basis. This translates to less than 60 m3 per capita, making Malta the most water scarce

country in Europe and amongst the top ten countries for water scarcity worldwide.

Groundwater status

Practically all of Malta’s naturally occurring freshwater is stored in groundwater bodies. Groundwater

is threatened mainly by nitrate pollution and over-extraction. 87% of Malta’s groundwater bodies

contain nitrate and/or chloride levels that exceed EU drinking water standards1. The main reasons for

this are nitrate contamination of rainwater in agricultural land, with sewage leakages into groundwater

bodies also being a contributing factor.

Groundwater is almost exclusively recharged by rainwater. The amount sustainably available for

extraction therefore depends on the amount of rainwater reaching groundwater bodies. Malta currently

extracts around 50% more groundwater than is sustainably available2. This results in deteriorating

quality of the remaining groundwater reserves. NSO statistics show that groundwater extraction has

been increasing on an annual basis3. This indicates that measures taken so far to counter over-extraction

have not achieved the desired result.

Reverse-osmosis

Malta does not have enough natural freshwater to meet its needs. This has forced the islands to rely on

alternate methods of generating freshwater, notably reverse-osmosis. This process takes seawater and

1Several sections of the Commission Staff Working Document dated 14.11.2012 reference code COM(2012)670Final

makes reference to the requirement for freshwater bodies to be restored to Good Status. Key amongst these is the following

statement on page 9 linking to Table 6.5“Only 2 groundwater bodies have good chemical status while 13 of them (87%) are

in poor status.”The working document may be viewed here:

http://ec.europa.eu/environment/water/water-framework/pdf/CWD-2012-379_EN-Vol3_MT.pdf 2Table 1 of the NSO press release dates 21

st March 2013 shows that groundwater abstraction is valued at 39.8hm3 in 2012:

http://www.nso.gov.mt/statdoc/document_file.aspx?id=3556

Chapter 10, pg 72 of the UN’s FAO, Malta Water Resources Review reads “Thus, the potentially abstractable groundwater

from all the groundwater bodies in the Maltese Islands is about 25 hm3. Any abstraction above this figure will lead to over-

abstraction with the consequential degrading in the quantitative and qualitative status of the groundwater bodies”:

ftp://ftp.fao.org/docrep/fao/009/a0994e/a0994e.pdf 3Table 1 of the NSO press release dates 21

st March 2013 shows that groundwater abstraction is valued at 39.8hm3 in 2012,

and 21.5hm3 in 2004:

http://www.nso.gov.mt/statdoc/document_file.aspx?id=3556

5

using high pressure membrane filtration desalinates it, making it suitable for drinking. The process

however, uses a lot of energy. Latest estimates conclude that around 4% of Malta’s electricity goes

towards generation of freshwater4, even given significant advances in the efficiency of this technology.

Reverse-osmosis is therefore an energy intensive method of producing freshwater.

Climate Change

Forecasts of changes to weather patterns caused by climate change, show that the Mediterranean could

see decreases of up to 15% in annual rainfall. Furthermore, this rain is likely to fall in more frequent

intense storm events, instead of being spread evenly over a period of time. This would lead to increased

rainwater runoff to the sea and therefore decreased groundwater recharge, further reducing the amount

of groundwater sustainably available for extraction on an annual basis.

EU Legislation

The Water Framework Directive includes an obligation to recover all costs related to water services,

including a resource and environmental cost, and the cost of managing wastewater having regard to the

social, environmental and economic effects of the recovery.

The Water Framework Directive also requires all groundwater bodies to be brought to ‘Good Status’ by

2015, and abstraction to be balanced with recharge. The former is difficult for Malta to meet, due to

natural recharge of groundwater bodies by surface water taking decades. This means that water already

en route to groundwater bodies could well be high in nitrates. For this reason Malta has been granted

extensions beyond the 2015 deadline. Over-extraction however, is currently at 50% above recharge.

This will need to decrease by 2015.

Summing up the environmental and resource problems of water in Malta; there is little natural water to

start with, demand is higher than supply leading to over-exploitation, this is impacting negatively on

quality of groundwater bodies, future supplies are further threatened by expected changes in rainfall

patterns, and the method in use to generate additional freshwater is energy intensive.

The Project partners would advocate a strategy consisting of both decreasing demand by increasing

efficiency, and augmenting supply by increasing the take-up of non-conventional water resources

produced both internally by consumers as well as produced externally and made available to

consumers.

4Table 3 of the NSO 2011 News Release lists national electricity consumption by reverse osmosis plants at 3.8%:

http://www.nso.gov.mt/statdoc/document_file.aspx?id=2988

6

Section3 - Measure specific recommendations

Affecting demand

Demand can be influenced through both consumer behaviour and the rolling out of more water-

efficient technology for household, business and industrial use.. Based on project experience, it is clear

that technology in use is often inefficient. The partners therefore advocate an approach prioritising

demand-management through technology over behaviour at this point in time. Demand management

through awareness raising aimed at affecting behaviour would however, even at this stage, be an

important supporting action.

The partners are confident that a significant reduction in consumption can be brought about by

informing consumers of efficiency in water consuming facilities. To this end the creation and

promotion of a water saving label on water-consuming appliances put on the market would be a good

soft measure for demand management. Further action can be taken by setting standards in water

consuming facilities, with goods not meeting these standards being made less attractive through

increased eco-taxation compared to efficient models, or outright bans as was done with the

incandescent bulbs. The development of standards on water-saving technologies has ideally to be

carried out and coordinated at an EU-level through mandates to be obtained with the full support of

industry. Industry stakeholder bodies should be involved from the early-stage of the process to ensure

that the best available technologies are brought and made available on the market for both household

and industry users.

To summarise, the demand-management tools recommended by the project are:

1) Water saving label for goods;

2) Promotion of water efficient technologies, through awareness raising coupled with financial

measures, namely eco-taxation for less efficient models.

7

Supply of non-conventional water resources

Public debate has focused strongly on the national provision of non-conventional water resources,

predominantly treated sewage effluent (TSE). Leaders within industry have shown that in-house

production of non-conventional water resources is an effective and efficient water management

method. The main alternative and sustainable sources used by industry are:

Treating waste-water:

sewage,

grey-water,

and industry specific waste-water.

Harvesting rainwater.

All the above forms of non-conventional water resources generation are economically attractive within

certain economies of scale. That makes the price of water a critical factor in the take-up of in-house

alternative water source generation. Given the expected reduction in the cost of water in 2014,

increasing the cost-effectiveness of implementing such technology depends largely on the cost of

technology. Mechanisms to reduce the impact of the capital costs of introducing such systems such as

grants, tax rebates, subsidies, soft loans, or other such financial mechanisms are being suggested.

The setting of quality standards for 2nd

class water would also be particularly helpful in encouraging 2nd

class waster use. This is particularly so for waste-water treatment applications, but also for rainwater

harvesting where rain could be harvested from roofs or other areas. In Europe no such standards exist,

and therefore the setting of these standards would ideally involve pan-European and EC level

recognition, to facilitate the replication of best practice throughout EU member states. However,

lacking an EU-wide standard, the setting of a national standard would support the wider adoption of

non-conventional water sources as 2nd

class water. Such a national standard could always be updated to

comply with an EU standard at a later date, or even support the identification of an EU-wide standard

by the relevant EU entity.

8

Measures - efficient consumption

Facts:

Showers, wash-hand basins and toilets account for between 40% to 90% of hotel’s water consumption,

and anything from 5% to 95% of business water consumption. Yet a strong element of over-design

exists. Showers delivering up to 30 litres per minute have been recorded by the project, as have toilets

with a 15 litre flush volume, or urinals consuming 2,500m3 per annum.

However, best practice examples existent in industry show that luxury 5 star hotels use a standard of 7

litres per minute for showers, and 5 litres per minute for wash-hand basins, while most toilet models

flush volume can be reduced to 6 litres. Toilets on the Maltese market with a flush volume of 4.5 litres

are also available.

Figures:

Adopting a standard 7 litres/minute flow rate for showers, 5 litres/minute flow rate for wash-hand

basins would save an estimated 349,500,000 litres per annum amongst hotels5. Exporting these

standards to other sectors, such as the domestic sector, would increase this figure considerably.

Suggested measures:

The partners advocate a two-pronged approach to an increased adoption of water efficient measures: a)

awareness raising, b) promotion of efficient hardware. To move towards a reduced consumption,

awareness of efficiency improvements needs to be driven as part of a demand management strategy,

ideally coupled with a supply management strategy where the development, wholesale and resale of

more water efficient hardware is encouraged. Using the EU LIFE+ Investing in Water Project as an

example - a project which estimated water savings of 141,000,000 litres per annum amongst

participating enterprises - awareness raising projects aimed at specific target audiences and focused on

face to face contact and the provision of technical advice, could result in tangible decreases in water

consumption. Measures for the management of the supply of water consuming hardware could range

from the establishment of a water efficiency Eco-Label, to a more aggressive phasing out of inefficient

water consuming hardware, as was done for lighting hardware with the phasing out of incandescent

bulbs. The focus here should be toilets, wash-hand basins, and showers as these are hardware used by

every sector and contributing to a significant consumption of water on a national level.

5 Paper; Greening the economy – Greywater treatment and flow rate regulation as a job generator, water, energy and CO2

saver 20th

Dec 2013. www.investinginwater.org

9

Financing of measures:

The creation of such a label could be done by government departments, financed through existing

budgets. The promotion of the label could be undertaken through a public-private partnership, public

funds, or through the involvement of several smaller awareness raising projects run by stakeholders

representing specific sectors. Alternatively, the creation and national promotion of such a label could

form part of a national-scale EU funded project involving stakeholder representatives of various

sectors. Amongst the funding streams that could be potentially tapped into for such a project are LIFE,

and structural funds, the new EIB schemes for the climate-change related projects, and last but not least

the capacity-building measures available via the ERDF and ESF operational programmes for the

current financing period 2014-2020.

Measures – harvesting rainwater

Facts:

Rainwater is an excellent source of 2nd class water low in dissolved solutes such as hardness, nitrate

and salt when collected from controlled and clean areas, such as roofs. Collecting rainwater in Malta

can be challenging due to the high intensity low duration rainfall events typical for the country, and the

fact that most of the rainfall is available in a few months every year, requiring large storage capacity to

carry over the water from the wet months to the dry months when rainfall is minimal or non-existent.

Rainwater harvesting is of little interest for the majority of hotels in Malta, due to the high rise nature

of their premises. This results in a high density of consumers for a very limited rainwater catchment

area, which leads to a rainwater harvesting meeting a negligible percentage of the demand (at times

recorded at 0.3% of demand). This relatively low supply-to-demand ratio makes it an unattractive

investment for hoteliers. On the other hand, rainwater harvesting is particularly attractive for industry.

Industry requires good quality, cheap, 2nd class water for use in various processes. Rainwater, with no

or minimal treatment and collected from factory roofs, meets these needs perfectly. Furthermore, with

factories often having very large collection areas it is possible to harvest a significant percentage, at

times even all, of an enterprise's demand.

10

Figures:

Employees Total

consumption

Estimated

toilet

consumption

Roof area Potential

rainwater

harvest

% 2nd

class

water

demand

met

Manufacturing 4,854 138,212 39,088 163,371 81,310 208.0178

Offices 2,049 16,953 15,879 19,203 9,557 60.18641

This shows actual data for a sample group of offices and factories, the presented figures can be

assumed indicative for industry as a whole. The table presents 2nd

class water demand as that required

for flushing toilets (in m3/year). Factories could also use 2nd

class water for industrial processes – and

there would be surplus harvested rainwater over the water required for flushing toilets which could

meet this demand.

Suggested measures:

Although the obligation to include a rainwater harvesting cistern in every premises has been law in

Malta for centuries, this is today rarely observed and even more rarely enforced. This holds for private,

commercial, or public buildings.

All new public buildings should be built with cisterns, and rainwater harvesting should be introduced

wherever possible. This includes buildings constructed and used by ministries, departments and

authorities, as well as schools and hospitals.

Existing public storm water cisterns seem to be a grey area in terms of ownership, maintenance and

who has the right to manage the collected rainwater. The result is that most of these public cisterns are

damaged or collecting water which nobody uses. If ownership, maintenance, and water management

rights could be allocated to one recognised body, this would remove the current obstacles to accessing

rainwater. This should be supported through a scheme supplying second class water to users in the

vicinity of the cisterns. An option is for the administration of the water to be delegated to local councils

as a means of promoting/controlling the take up of this water. This may also provide a source of

revenue to local councils which may fund water initiatives among the community. Regardless of the

controlling entity, an element of cost recovery could be incorporated into the scheme by charging for

consumed rainwater there is also significant potential for incepting public private partnerships whereby

the management of public cisterns can be devolved to the private sector in exchange for the proper

maintenance of the infrastructure. Demand for rainwater from public cisterns on industrial parks and

11

agricultural areas already exist.

The development of a 2nd

class water standard would support a widespread adoption of rainwater

harvesting, particularly coupled with guidelines on collection and use of rainwater to prevent 2nd

class

water being used in 1st class applications.

Financing of measures:

Addressing the ownership issue is a matter of governance which could be decided at ministerial level,

with the main costs being government personnel costs. This should be covered through national budget.

Once addressed the main cost-incurring aspect to providing harvested rainwater is the maintenance cost

of the cistern and delivery system. An element of cost-recovery should be included in the provided

rainwater, through a meter and unit-consumption charge. The cost would have to be attractive, taking

into consideration the availability of mains water, and unsustainable bowser supplied groundwater.

Measures - treating waste-water

sewage,

grey-water,

and industry specific waste-water.

Facts:

Treating and reusing waste-water is becoming increasingly technologically and economically viable.

Waste-water can be treated up to 2nd class standards for general use, up to standards required for a

specific application (this holds particularly in the case of industry-specific waste-water), or even up to

1st class, i.e. potable, standards. Industry in particular is a leader in this regard, with several enterprises

having operated waste-water treatment plants for many years already, with excellent results.

Acceptance of treated waste-water is therefore probably higher amongst industry than amongst certain

other sectors.

Figures:

The main quantification the project has carried out relates to a wide-spread adoption of grey-water

treatment by the hotel industry. This shows that grey-water treatment could lead to a hotel industry-

level reduction in consumption of around 490,000 m3 per annum, representing savings of around EUR

12

940,0006. The savings take into consideration the fact that industry uses both in-house reverse-osmosis

generation of freshwater as well as WSC supplied mains water, however does not take into

consideration the use of bowser supplied water, or illegal sources of water including seawater. The cost

of such a wide-spread adoption would be in the region of EUR 3,800,0007.

No quantification for the adoption of sewage treatment or industry specific waste-water treatment has

been carried out by the Project. The main reasons are that the scope for in-house sewage treatment at

this point in time is limited, largely due to the investment costs requiring a significant economy of

scale, and the space requirements which rule out the vast majority of enterprises from adopting such a

solution. Nevertheless, it must be pointed out that in-house sewage treatment would be preferred over

grey-water treatment as a larger percentage of the enterprise's water can be recycled. Industry specific

waste-water treatment is also difficult to quantify, largely due to Malta having no particularly large

water consuming industries apart from the hotel industry. Plants would therefore need to be

customisable given the waste-water produced, and characteristics of 2nd class water required, by

different industrial operations. The scale of applicability for industry specific waste-water treatment for

water recovery is also believed to be low however; this has also proven to be an attractive water-saving

measure when applicable.

Suggested measures:

The main target audience for this water-saving measure is the hotel industry, for the reasons stated

above. If the MTA were to adopt a policy incentivising the voluntary best-practice adoption and

implementation in hotel investment plans of grey-water treatment, the adoption of this technology

would automatically take off. Initially hotels with foresight and a view to environmental and operating

cost sustainability would take advantage of the policy. With such industry leaders in the hospitality

sector setting the pace, hesitant operators would soon catch up with these standard- setters.

New hotels as well as those undergoing infrastructural renovation or significant extensions should be

encouraged to introduce grey-water harvesting. An adequately-financed public policy supporting such

measures in the shape of grants would be a key factor in bringing about the widespread adoption of

grey-water treatment. A more detailed proposal is listed Section 4.1.

Financing of measures:

The main financial involvement of this measure would be the provision of a financial instrument for

industry. This could be accomplished through the use of structural funds, or the use of instruments such

as Jeremie.

6 Paper; Greening the economy – Greywater treatment and flow rate regulation as a job generator, water, energy and CO2

saver 20th

Dec 2013. www.investinginwater.org 7 Paper; Greening the economy – Greywater treatment and flow rate regulation as a job generator, water, energy and CO2

saver 20th

Dec 2013. www.investinginwater.org

13

Section 4 – Supporting Documentation

Note – these recommendations have already been passed onto the Ministry for Energy and Health as

well as the Ministry for Sustainable Development, the Environment and Climate Change, and the Malta

Tourism Authority. They are being attached to this document for ease in reference.

Greening the Economy Recommendations

Recommendations - Grey-water treatment as a Green Economy Initiative

Submitted to the Chair of the Greening the Economy Core Group

By the Malta Business Bureau’s EU LIFE+ Investing in Water Project

Published on 20th December 2013

Contents

Contents ................................................................................................................................... 13

1. Background .......................................................................................................................... 14

2. Description ........................................................................................................................... 14

2.1 A grey-water treatment policy for new hotels/hotels undergoing infrastructural renovation 15

2.2 Awareness raising for hotel operators about the benefits of grey-water treatment ...... 16

2.3 Grants – funding grey-water treatment ......................................................................... 16

2.4 Suggested timeline.......................................................................................................... 18

3. Desired outcome .................................................................................................................. 18

4. Benefits to increased grey-water adoption ........................................................................... 19

4.1 Generation of Green Jobs .............................................................................................. 19

4.2 Water and energy savings .............................................................................................. 19

14

1. Background

The hotel industry could reduce its water consumption by up to 20% if in-house grey-water treatment

were widely adopted. This measure would contribute to the improvement of industry’s competitiveness

by reducing costs, and benefit Malta by reducing pressure on scarce natural water resources, saving

energy required in the production of reverse-osmosis water, and generate a number of additional jobs in

the private water treatment sector.

2. Description

The EU LIFE+ Investing in Water Project has audited 45% of the hotels in Malta and Gozo. The audits

have highlighted key water saving measures which would yield significant savings, are widely

available on the local market, and are financially feasible offering reasonable return on investment

periods.

Key amongst the water saving measures is in-house treatment and use of grey-water. Grey-water is the

waste water from showers and wash-hand basins, and not being as contaminated as black-water

(sewage), requires less technically intensive treatment to bring up to a suitable 2nd

class water quality.

Widespread greywater adoption could result in an industry-wide reduction in water consumption of up

to 20%.

Malta could move to a situation where water consumption in hotels is drastically reduced. To bring this

about an increased emphasis on grey-water treatment needs to be made. This could be brought about

through:

1) A grey-water treatment policy for new hotels/existing hotels undergoing infrastructural renovation8, or

expanding considerably;

2) Awareness raising for hotel operators about the benefits of grey-water treatment;

3) Financial grants supporting the necessary investments into grey-water treatment facilities in existing

hotels.

8 Hotels undergoing infrastructural renovation are defined as hotels for which the bathrooms are being re-furbished allowing

for plumbing to be upgraded through the separate collection of grey-water (waste shower and wash-hand basin water) from

black-water (waste toilet water), and the distribution of 2nd

class water to toilets.

15

2.1 A grey-water treatment policy for new hotels/hotels undergoing infrastructural

renovation

If the MTA were to adopt a policy incentivising the voluntary best-practice adoption and

implementation in hotel investment plans of grey-water treatment, the adoption of this technology

would automatically take off. Initially hotels with foresight and a view to environmental and operating

cost sustainability would take advantage of the policy. With such industry leaders in the hospitality

sector setting the pace, hesitant operators would soon catch up with these standard-setters

Both new hotels as well as those undergoing infrastructural renovation or significant extensions should

be encouraged to introduce grey-water harvesting. An adequately-financed public policy supporting

such measures in the shape of grants would be a key factor in bringing about the widespread adoption

of grey-water treatment.

Such a policy should take into consideration hotels’ economies of scale. Technology currently on offer

in the local market should be evaluated to determine a minimum size of plant for which a financially

attractive return on investment is offered. Hotels meeting, or exceeding, a 2nd

class water demand

which would be met by such a plant should be strongly incentivised to adopt grey-water treatment.

Hotels which fall below this minimum could be provided with direct and commensurate financial

assistance which will make good for the higher cost per unit of smaller plants.

This policy should ideally ensure that the technology available on the local market is regularly

reviewed. The waste water treatment sector is experiencing rapid improvements in availability and

affordability of technology, and the minimum-size of plant to offer an attractive return on investment is

therefore expected to decrease over the short term.

This recommendation is based on experience of the EU LIFE+ Investing in Water Project with existing

hotels running grey-water treatment plants. Based on this experience, the widespread promotion of

grey-water treatment is considered a feasible commercial investment solution for hotel operators. Grey-

water treatment is a waste water treatment type, which the EU LIFE+ Investing in Water Project has

identified as being most transferable in the case of Malta’s hotels. The reason for this is that:

1) Space can generally be found for a properly sized greywater treatment system;

2) Return on investment period is attractive;

3) The technology is easy to maintain by non-dedicated personnel;

4) Investment costs are not prohibitive for most enterprises;

5) It caters for a relatively low 2nd class water demand.

It should be noted that the other main waste-water treatment option that is applicable to Malta’s hotels

16

is in-house black-water treatment (sewage treatment). This option is not as widely applicable as grey-

water treatment, mainly due to space requirements, the need for a much higher 2nd

class water demand,

larger initial investment costs, and maintenance being more demanding. However, it is a very attractive

water saving option for those hotels for which it is applicable. Any policy aimed at the widespread

adoption of grey-water treatment should therefore not make this treatment compulsory in the case that a

hotel has the circumstances and intent of investing in black-water treatment. In such a case, priority

should be given to the black-water treatment.

2.2 Awareness raising for hotel operators about the benefits of grey-water treatment

Having carried out audits in nearly half of Malta and Gozo’s hotels, the EU LIFE+ Investing in Water

Project has identified the three operational grey-water treatment plants. The small number of plants

currently operational is due to the relatively new status of this technology in Malta. Despite its relative

novelty, the project notes that the hotels operating these plants are very satisfied with the performance

and benefits reaped.

During the audits it became apparent that more awareness is needed amongst operators of the

availability, requirements, and benefits of grey-water treatment. The partners feel that for a grey-water

treatment policy to be successful levels of awareness will need to increase. To support this policy, the

partners are willing to continue communications with hotel operators beyond March 2014, the end of

the EU LIFE+ Investing in Water Project, regarding grey-water treatment.

The Malta Tourism Authority would be an asset in supporting a grey-water treatment policy through

communications aimed at increasing levels of awareness amongst hotel operators. The MHRA and

MBB are confident that with both the industry representative organisation (MHRA) as well as the

industry national authority (MTA) communicating grey-water treatment, levels of awareness will

continue to rise leading to a tangible take-up of the technology over the short-medium term.

2.3 Grants – funding grey-water treatment

To facilitate the take up of grey-water treatment, a grant scheme offering existing hotels attractive co-

financing rates for grey-water treatment plants and related infrastructural costs should be made

available.

Grey-water treatment technology currently has a minimum threshold for an attractive return on

investment. Project experience suggests this is around 25 m3 per day. Since waste-water treatment

17

technology is steadily and quickly advancing, leading to improved technology available at reduced cost

on a regular basis, this figure should be confirmed prior to the formalisation of a policy encouraging

the voluntary implementation of grey-water treatment.

Grants should be available which existing hotels intending to implement grey-water treatment could tap

into. Such grants would ideally have higher co-financing rates for smaller projects. This would ensure

that smaller hotels which would therefore find the higher relative cost of grey-water treatment a burden,

are given a commensurate level of support which would make good for the increased costs of

installation that come with a smaller economy of scale.

Grants should also cover the plumbing works that go hand in hand with installing a greywater system.

This consists of plumbing to drain grey-water to the treatment plant, and a 2nd

class water distribution

system to make use of the treated greywater.

It should be pointed out that it is unlikely that a high percentage of hotels will implement grey-water

treatment on a short term basis, as greywater systems generally require some modification to the

plumbing network. This upgrade would therefore best be implemented during major refurbishing works

or when significant extensions are carried out to the properties. New hotels should all be robustly

incentivised to install a grey-water treatment plant, or alternatively a black-water treatment plant if

conditions are suitable.

Due to the need for infrastructural renovations in most hotels to accommodate greywater installations,

it is likely that only a small numbers of hotels will implement grey-water treatment on an annual basis.

The funding scheme should therefore take this into consideration, noting that it is highly probably that

a small percentage of hotels will apply for funding on an annual basis, but that this demand would be

constant over the medium term following the scheme’s announcement. The funding scheme should

therefore be made available over a medium term period, and re-evaluated at the end of that term.

It is also important to note that when hotels compare financial gains from energy or water saving

projects, other initiatives might offer a higher return on investment. Examples of such projects in the

current economic environment include energy saving lighting and heating projects. A grant scheme

focused on the investment in grey-water treatment solutions by existing hotels, should ensure that

operators are not forced into adopting grey-water treatment instead of other energy and/or water saving

initiatives which would be more financially attractive. The ideal situation is to have operators

financially assisted in investing across the whole range of energy-saving practices, rather than forced to

opt for one solution instead of another(s) due to budgetary restraints.

In addition, the grant should be structured to counter the lack of liquidity which many of the smaller

hotels experience. An instrument offering delayed payment, such as through a tax rebate or credit,

would not counter the root difficulty of low liquidity. Conversely, a grant based on advance payment

would help operators meet with the initial investment costs without any adverse impact on their cash

18

flow.

During the previous programming period, existing hotels could apply for EU funding through the

‘Grant Scheme for Sustainable Tourism Projects by Enterprises’, funded through the ERDF structural

funds. During the next programming period (2014-2020), a similar scheme could be considered,

through which existing hotels would be able to finance grey-water treatment projects. It should be

noted however, that through the previous call hotels could not fund measures which were made

mandatory through an MTA related Legal Notice. Compliance-related costs were and remain ineligible

for EU funding assistance. This is particularly important since proper consideration should therefore be

given in identifying the right policy mechanism through which grey-water treatment solutions in

existing hotels will be encouraged in the coming years. A non-mandatory, voluntary based but supply-

side incentivised approach is consequently the most feasible measure that we advocate to be adopted by

the authorities in order to promote a faster and wider uptake of grey-water treatment practices by hotels

irrespective of size and prospective investment plans.

2.4 Suggested timeline

2014 Q1 identification of minimum size for grey-water treatment plants in hotels

2014 Q2 stakeholder consultation and conclusion of grey-water treatment policy for hotels

development of funding package

MHRA and MBB communications with operators regarding grey-water treatment

2014 Q3 adoption of grey-water treatment policy for hotels

commencement of funding package

MHRA and MBB communications with operators regarding grey-water treatment

3. Desired outcome

This policy would yield benefits in the medium to long term. Within five years of adoption all new

hotels and hotels which have undergone infrastructural renovations will have grey-water treatment

systems. This will represent a minority percentage of hotels in Malta. However, within 15 years, as

more new hotels are developed and many hotels undergo infrastructural renovations most of the hotels

on the islands will have grey-water systems.

19

4. Benefits to increased grey-water adoption

Widespread adoption of grey-water treatment by the hotel industry would benefit Malta mainly through

a reduced water and electricity consumption, and through the creation of a number of additional jobs.

4.1 Generation of Green Jobs

The EU LIFE+ Investing in Water Project estimates that if all hotels were to implement grey-water

treatment systems this would result in the generation of between 13 and 20 full time equivalent

positions in the private water treatment sector. The jobs would be generated as follows:

Installation - 97,500 man hours in installation, which equate to slightly more than 10 full time jobs

for 5 years (assuming all installations are carried out in 5 years), or 3 full time equivalent jobs if all

installations are carried out over a 15 year period.

Operation - 7 full time job equivalent (for as long as the plants remain operational)

Maintenance - 3.5 full time job equivalent (for as long as the plants remain operational)

4.2 Water and energy savings

For an estimated cost of EUR 3,816,500 the hotel industry could adopt grey-water treatment, resulting

in annual savings of EUR 979,000 on water bills, leading to a repayment on investment period of just

under 4 years. This measure would also result in the industry saving 492,000 M3

of water per annum.

National electricity savings in the production and distribution of water would reach 2,301,120

kWh/year.

While figures for savings are dependent on guest nights per annum, the guest night per annum figures

used in the presented calculations were obtained directly from hotels audited by the EU LIFE+

Investing in Water Project, and cover 2011 and 2012 for individual hotels. The total savings will

therefore fluctuate from year to year as guest nights per annum fluctuate, however since in Malta this

fluctuation is not severe, the savings figures fluctuations will be relatively minor.

The benefits listed above are explored in more detail in the following paper: Cremona, M; Saliba, G;

2013, Greening the Economy – grey-water treatment as a job generator, water, energy and CO2 saver,

MBB EU LIFE+ Investing in Water Project. This paper is attached as Annex 1 to this document, and

available for download from www.investinginwater.org/downloadables/

20

Annex 1

Paper

Greening the economy – Greywater treatment and flow rate regulation as a

job generator, water, energy and CO2 saver

By the Malta Business Bureau’s EU LIFE+ Investing in Water Project

Published on 20th December 2013

Author: Ing. Marco Cremona, Water Expert to the MBB’s EU LIFE+ Investing in Water

Project

Co-Author: Geoffrey Saliba, Project Manager to the MBB’s EU LIFE+ Investing in Water

Project

Abstract

The EU LIFE+ Investing in Water Project has identified that an industry wide adoption of

shower and wash-hand basin flow rate regulation, and grey-water treatment by hotels could

lead to considerable savings in water and electricity consumption. The adoption of these three

water saving measures would lead to an industry level reduction in water use of 37%, and

significant energy savings on heating.

This paper is based on water audits carried out by the project in 63 hotels over the period

February 2012 to December2013, representing 45% of hotels in Malta. This paper explores

the contribution of these key water saving measures to the Green Economy, and is a follow

up to the project paper titled ‘The Hotel Industry – a shift to greener, lower cost operations’

published by the projection the 27th September 20139.

9 This paper may be downloaded from the project website www.investinginwater.org/downloadables/

21

An industry wide adoption of key water saving measures

Experience carrying out water audits in nearly half of Malta’s hotels shows that the three key

water saving measures are:

Flow rate regulation of showers

Flow rate regulation of wash-hand basins

Grey-water treatment and use

Optimal flow rates for showers and wash-hand basins were identified based on best practice

implemented in key 5* hotels. During the audits, it was observed that most showers and

wash-hand basins taps were issuing water at flow rates that were higher that these optimal

flow rates, sometimes multiple times the recommended values.

Regulating these flow rates would result in considerable water savings. Given that showers

and wash-hand basins also use heated water, regulating flow rates would also result in a

reduction in energy used for water heating. Experience from the water audits carried out in

hotels in Malta has shown that this energy reduction actually generates greater financial

savings than those achieved through reduced water consumption.

In addition, hotels have a high demand for 2nd class water used mainly for flushing toilets,

floor washing, and landscaping. In some cases 2nd class water use makes up for as much as

40% of total water use within the hotel. This demand can be met through grey-water recycling

– which is the in-house treatment of shower and wash-hand basin wastewater to 2nd class

quality for re-use.

An industry wide adoption of these three measures would result in the below estimated

savings:

Hotels Wash-hand basins Showers

Grey water recycling potential

(minimum)

% of current consumption

5 star 2.51% 9.00% 18.26% 29.77%

4 star 4.14% 14.28% 21.38% 39.8%

3 star 4.68% 5.70% 27.01% 37.39%

Totals 3.73% 12.05% 21.75% 37.53%

Table 1: Savings as a proportion of total water consumption, by hotel category

22

Financial savings through industry wide adoption of key water saving measures

The project has calculated the volumes that can be saved from the implementation of key

water saving measures and the monetary value of the savings arising thereof. In order to do

so the project used water consumption and guest night data tied to 2011 and/or 2012, as

provided by audited hotels. Actual savings will depend on the guest nights, and therefore, as

guest nights fluctuate slightly from year to year, the savings presented below can also be

expected to fluctuate slightly from year to year.

1.1 Savings in water

In absolute volumes, the water savings that can be accrued from the implementation of the

above mentioned water saving and water recycling measures are tabulated below.

Hotels Wash-hand basins Showers Grey water

recycling potential (minimum)

Totals

5 star 21,000 75,400 153,000 249,400

4 star 49,800 171,700 257,000 478,500

3 star 14,200 17,300 82,000 113,500

Totals 85,000 264,400 492,000 841,400

Table 2: Water savings arising from the implementation of water saving solutions in hotels (in

m3/year)

These figures have been arrived at by using the results in Table 1, and actual water

consumption figures for 2011/2012. The figures therefore reflect the hotel occupancy levels in

2011 and 2012, as well as the water use practices pertaining to these years. As hotel

occupancy levels fluctuate slightly from year to year, so too will the savings figures.

Assuming that 80% of 5 star hotels get their water from their own seawater RO plants, falling

to 60% of 4 star, 5% of 3 star and 0% of 2 star, out of a total 2,354,000 m3 of water used by

hotels, then it can be seen that:

1,406,824 m3 of the total water used by hotels comes from hotel RO plants (60%)

947,176 m3 comes from the Mains water supply (40%)

At an estimated unit cost of EUR 1.65/m310 for RO water, and EUR 2.50/m3 for mains water,

10

includes amortisation of the RO plant over 15 years

23

the total cost of production of water used by hotels in Malta works out at EUR 4,689,200/year

or EUR 1.99/m3 on average. So, for a total savings of 841,400 m3/year at an average unit

cost of EUR 1.99/m3, annual monetary savings become EUR 1,674,386.

2.2 Savings in energy

2.2.1 Savings in Electricity (kWh/year)

Table 3 shows the amount of electricity that can be saved from the national electricity grid (in kWh/year) if all hotels were to adopt restrictors on taps or showers (or use water saving showerheads), and if all hotels were to install greywater systems. The calculations assume that all the hotels in Malta are using town water and/or RO (i.e. bowser water supplies and the use of seawater for the flushing of toilets are not considered) and the energy saved is therefore the electricity saved in producing this water. This also includes the electricity used by WSC in producing the water and delivering it to the hotels.

Hotels

Wash-hand basins Showers Grey water

recycling potential (minimum*)

Totals

5 star 106,900 383,300 701,200 1,191,400

4 star 257,000 886,500 1,198,800 2,342,300

3 star 76,600 93,300 401,100 571,000

Totals 440,500 1,363,100 2,301,100 4,104,700

Table 3: Electricity savings by implementing water saving measures (in kWh/year)

Assuming the cost of electricity at EUR 0.15/m3, as at current commercial prices, the total

monetary savings in electricity amounts to EUR 615,705/year.

24

2.2.2 Savings in Fuel (litres/year)

Given that around 50% of the water used in showers and wash hand basins in guest rooms is

hot water, any savings in water will result in a savings of fuel used in boilers to heat up the

water that is used by guests in the guest rooms.

The fuel savings are calculated on the basis of information obtained from three hotels which

implemented flow regulation devices (restrictors) on showers and wash-hand basins. These

hotels used fuel to heat water, at a requirement of 8 litres of fuel per m3 of heated water. This

figure may vary for other hotels, depending on the size and efficiency of their heating

systems. Additionally smaller hotels may use electric geysers to heat water, while some have

over recent years also installed solar water heaters. Nevertheless, since the majority of hotels

use boilers for heating their water, the information shown in Table 4 is a useful indication of

industry level fuel savings.

Hotels Wash-hand basins Showers Grey water

recycling potential (minimum*)

Totals

5 star 427,600 1,533,300 0 1,960,900

4 star 1,028,100 3,546,200 0 4,574,300

3 star 56,800 373,200 0 430,000

Totals 1,512,500 5,452,720 0 6,965,520

Table 4: Fuel savings (in litres per year) arising from the implementation of water saving

solutions in hotels

Note that there are no direct fuel savings with greywater recycling because treated greywater

is used for the flushing of toilets and therefore does form part of the hot water system of the

hotel.

The hotels for which the project calculated savings on heating were purchasing fuel at EUR

0.87 per litre. Using this figure, and extrapolating on a national level, fuel savings are

estimated at EUR 5,970,000/year.

25

2.3 Cost of implementation

Based on a technical and economical evaluation of a top-of-the-range and a basic greywater

system operational in two local hotels, the project estimates the following:

For 5 star hotels, for which the average greywater system size is 27.6 m3/day, a greywater

system for a hotel would cost between EUR 40,000 – EUR 115,000 (depending on technology

and distribution of hotel), with an average cost of EUR 75,000 per installation

For 4 star hotels, for which the average system size is 17.5 m3/day, greywater systems would

cost between EUR 20,000 – EUR 60,000 (depending on technology and distribution of hotel),

with an average cost of EUR 40,000 per installation

For 3 star hotels, for which the average system size is 6.5 m3/day, greywater systems would

cost between EUR 12,500 – EUR 15,000, with an average cost of EUR 13,500 per installation

For 2 star hotels, for which the average system size is only 2.4 m3/day, greywater systems

would cost between EUR 8,000 – EUR 10,000, with an average cost of EUR 9,000 per

installation

Apart from the installed cost of a greywater treatment plant, these costs include the cost of

the separate greywater supply pipework required to convey greywater from the guest rooms

to the greywater treatment plant and the cost of a greywater-receiving reservoir/tanks and

some storage for the treated greywater. (The cost of a distribution system that conveys

treated greywater to the toilets in the premises is not included, because some hotels already

have this infrastructure in place).

The total costs per hotel category are therefore estimated to be:

5 star : EUR 1,125,000

4 star : EUR 1,760,000

3 star : EUR 742,500

2 star : EUR 189,000

The total industry investment cost in greywater infrastructure is therefore estimated to be EUR

3,816,500. The net annual savings offered by grey-water treatment are estimated to be EUR

942,200. The repayment on investment period would therefore be just under 4 years.

The cost of implementing flow regulation devices is calculated below. This assumes that only

75% of rooms will need to amend flow rates, with the 25% already meeting recommended

flow rates. The amendment considered is the use of water saving shower heads and

restrictors for wash-hand basins. Some hotels will be able to regulate their flows using

existing infrastructure such as pressure regulators. Others may opt for restrictors fitted to

shower heads, with a consequent decrease in investment cost.

26

The figures presented below should therefore be considered the higher end of potential

investment costs.

Number of rooms

Cost of restrictors Cost of shower head

Totals

5 Star 3562 EUR 5 EUR 32 EUR 98,900

4 Star 7209 EUR 200,000

3 Star 5159 EUR 143,100

2 Star 636 EUR 17,600

Totals 16,566 EUR 459,600

The savings arising from the implementation of these measures would be 349,400 M3 per

annum, representing financial savings of EUR 695,300. Add to this the savings on heating

due to less hot water being used, and savings could increase by an additional EUR

5,970,000/year. The repayment period would therefore be around 1 month.

27

2. Generating jobs through industry wide adoption of key water saving measures

Of the three key water saving interventions the regulation of showers and wash-hand basins

are the easiest to implement, and can be done by existing engineering or maintenance staff

within hotels. It is usually a one-time small intervention to the water system and would

therefore not result in any new jobs being created.

Widespread adoption of grey-water treatment would however entail an element of job creation

– through the installation of such systems in hotels, but also through the operation,

maintenance and occasional troubleshooting that would be necessary to keep the systems

operational. It should be noted that at present only 3 out of 138 hotels in Malta are equipped

with greywater recycling systems.

To estimate the number of jobs that may be generated by adopting greywater systems as the

state-of-the-art in all hotels in Malta the number of hours required for installing, operating and

maintaining different sizes of greywater systems was first estimated. The summation of the

man hours for 138 installations in all hotels in Malta then gave the full-time green job

equivalent on an industry wide basis.

This resulted in:

Installation - 97,500 man hours employed in the installation of greywater systems, which

equate to slightly more than 10 full time jobs for 5 years (assuming all 138 installations are

carried out in 5 years).

Operation - 7 full time job equivalent (for as long as the plants remain operational)

Maintenance - 3.5 full time job equivalent (for as long as the plants remain operational)

The total number of jobs that are estimated to be generated through an industry wide

adoption of grey-water treatment is therefore 20.5 full time equivalent.

When considering that the private water treatment industry in Malta currently employs 20-25

full time equivalent positions, this industry-wide installation of greywater systems would nearly

double the current work-force engaged privately in waste water treatment. Moreover, all the

jobs qualify as Green Jobs as they directly relate to the recycling of wastewater.

28

3. Environmental benefits to industry wide adoption of key water saving measures

3.1 Estimated water savings

Malta is one of the world’s top ten countries for water scarcity. With only an estimated 70m3

of naturally occurring freshwater per capita, there is simply not enough water to meet the

country’s demands. Consequently, Malta has to produce water artificially, using energy-

intensive seawater desalination (by a process called Reverse Osmosis) to meet its demands

and this has an impact on Malta’s carbon footprint.

Malta is currently estimated to extract over 50% more groundwater than is sustainably

available. Since main water is a 45-55% mix of groundwater to reverse-osmosis water,

increasing the efficiency with which water is consumed serves to directly reduce the pressure

on groundwater sources.

The adoption of these three key water saving measures is estimated to save around 841,400

m3 per annum. Of this, 701,800m3would be reverse-osmosis water generated through hotel’s

in-house units or forming part of the mains supplied mix, while 139,600 m3 would be

groundwater forming part of the mains supplied mix.

4.2 Estimated energy savings

Energy savings would be achieved through a reduced demand for reverse-osmosis water,

and through a reduced demand for heated water through more efficient flow rates in showers

and wash-hand basins.

The maximum amount of heating fuel saved is estimated at 6,965,200 litres translated into

direct monetary saving for industry. The amount of electricity saved from the national

electricity grid is estimated at 4,104,700 kWh/year. Part of this cost is incorporated in the

WSC water tariff, and therefore would not appear as an additional monetary saving for

industry. It does, however represent an annual monetary saving for the country, and a

reduction in CO2 emissions.

29

Conclusions

The cost of equipping all hotels in Malta has been estimated at EUR 3,816,500. This

investment would return water savings of approximately EUR 942,200, leading to a

repayment on investment period of just under 4 years.

This measure would result in the creation of an additional 20.5 full time equivalent jobs within

the private waste-water treatment sector, representing what is almost a doubling in the

current workforce. This measure would also result in the industry saving 492,000 M3 of water

per annum. National electricity savings in the production and distribution of water would reach

2,301,100 kWh/m3 per year, primarily from the reduced production and distribution of RO

water.

Add to that flow rate regulation of showers and wash-hand basins, and the savings increase

as follows:

Investment required EUR 4,276,000

Water volume saved 841,400 M3/annum

Heating fuel volume saved 6,965,520 litres/annum

Total financial savings EUR 7,806,920 per annum

ENDS

For further information please contact:

Geoffrey Saliba

Project Manager

EU LIFE+ Investing in Water Project

Malta Business Bureau, Cornerline, Dun Karm Street, Birkirkara BKR9039

Tel: +356 21 251 719 | E-mail: gsaliba@mbb.org.mt

Website: www.investinginwater.org - www.mbb.org.mt

The Malta Business Bureau thanks the EU LIFE+ Investing in Water Project partners the Malta Chamber of

Commerce, Enterprise and Industry and the Malta Hotels and Restaurants Association for the support provided

in carrying out meetings and water audits amongst enterprises. It also thanks the ministry responsible for the

environment, EasyDry Malta, APS Bank, Island Hotels Group, MSV Life for their financial support without which

it would not have been possible to carry out the project. In addition, all the participating enterprises receive a

special note of appreciation for collaborating with the project.

30

For more information:

Joe Tanti

MBB CEO

Cornerline, Dun Karm Street, Birkirkara

ceo@mbb.org.mt or 21 251 719

Project partners:

Project co-financiers and sponsors:

Ministry for Energy and Health

Ministry for Sustainable Development, the Environment and

Climate Change