If it acts like water breathing I would keep the same level as water breathing.
If it is more restrictive (self-only, no ritual casting, more expensive to use, etc.), then I would lower the level based on the change.
If it were less restrictive (effects more targets, easier to cast, adds extra effects other then breathing, etc) than I would raise the level based on the additional benefit the spell offers.
As described above I would leave it the same level as water breathing.
I personally wouldn't even make a new spell, but rule that the current one could be used in such situations for the same effect.
I also wanted to point to DMG page 283, which has this to say about creating spells:
When creating a new spell, use existing spells as guidelines.
Here are some things to consider:
- If a spell is so good that a caster would want to use it all the time, it might be too powerful for its level.
- A long duration or large area can make up for a lesser effect, depending on the spell.
- Avoid spells that have very limited use, such as one that works only against good dragons. Though such a spell could exist in the world, few characters will bother to learn or prepare it unless they know in advance that doing so will be worthwhile.
- Make sure the spell fits with the identity of the class. Wizards and sorcerers don"t typically have access to healing spells, for example, and adding a healing spell to the wizard class list would step on the cleric's turf.
Following this I would specifically emphasize the following:
When creating a new spell, use existing spells as guidelines.
In this case, water breathing - and:
Avoid spells that have very limited use
Unless the spell will have a larger presence, such as a game where water creatures are commonly needing it, then it would be better covered by allowing the water breathing spell to work for this purpose instead of making a new spell for the effect.