The south coast club have been offered membership by the Football League when the club manages to find new investment, but the outfit will automatically be served a 10-point penalty.
"We are extremely disappointed that the Football League has decided to impose yet another penalty on the club," said Birch.
"I think most people would agree that the 10-point deduction imposed last season was sufficient, particularly as it played a huge part in the club's relegation to League One.
"The fans, players and staff have suffered enough for something for which they weren't responsible. We feel it is unjustified for the club to be punished further."
Portsmouth have had just eight first-team players turn up for training this week.