The NFU is urging growers to respond to Defra's abstraction licence consultation, which proposes for all abstraction licences to be transferred into permits.
Growers with an abstraction licence are being encouraged by the union to register their views on the government's proposed changes.
The consultation applies to abstraction in England only, but similar provisions are being developed in Wales.
Defra wants to transfer water resources legislation into the Environmental Permitting Regulations (EPR), meaning all abstraction licences would be transferred into permits.
From a fixed date not yet specified, all existing abstraction and impounding licences will automatically and legally become environmental permits referred to as ‘converted permits’.
The NFU says it opposes the proposed changes, as the activity of abstraction is a 'poor regulatory fit for EPR'.
The union says the plans would lead to reduced certainty of access to supplies of water because all permits will be reviewable by the Environment Agency.
And abstractors would face the erosion of historic rights, it adds, as EPR includes no compensation provisions.
Existing licence holders will automatically become ‘operators’, as defined by EPR, for the duration of the term of the converted permit.
Defra says existing conditions in the licence will remain the same and there will be no re-issue of any documents as part of the move.
The NFU is urging growers to respond before the consultation's deadline, set at 22 December 2021.
"The consultation deals with complex legal issues such as appeals, compliance and enforcement, vesting of permits and duties for climate change adaptation and the NFU has developed clear positions on each topic," the union said.
"We hope that you will submit your own response even if your comments are limited to the importance of abstraction to your farm business and the overall impact that this regulatory upheaval will have.
"All responses will help inform Defra's consideration of the proposals. Have your say before the consultation closes on 22 December."
