The National Chicken Council filed comments with the U.S. Department of Agriculture’s Grain Inspection, Packers, and Stockyards Administration that explained why the interim and final rules proposed are bad for their industry. The NCC calls the rules “ill-advised,” saying they would cost American agriculture billions of dollars in economic damage, exceed GIPSA’s authority, and represent an arbitrary abuse of federal authority. NCC President Mike Brown says in the comments that GIPSA failed to provide any justification for the sweeping rule changes forced upon the poultry industry. “GIPSA doesn’t explain what benefits would offset the billions of dollars in harm this will cause the American economy,” Brown says. “The agency also fails to take into account the negative effect on consumers, innovation, competition, and even food safety.” Brown says his organization is particularly concerned about a potential storm of litigation that may result from the new rules. He says the new rules appear designed to create uncertainty and litigation, saying that even GIPSA admits costly litigation will ensue. Eight different Courts of Appeals have rejected a key part of the new rules which say a litigant would need to prove competitive injury to demonstrate a violation.