Comment 2: Vecchio, Richard J.

The technical premise for this proposed rule, at least in the case of Peruvian Pisco, is erroneous. Pisco is a distilled spirit, NOT a brandy because it is not stored in wood casks. Authentic Pisco requires an average of 8 kilograms of grape per liter (the equivalent of 8 bottles of wine for just one bottle of pisco). Unlike other spirits, no sugar is used as a catalyst for fermentation. The freshly fermented grape brew is then distilled in copper pot stills. No water is added. The pisco is aged in traditional mud-ceramic containers called “botijas” for three months to a year for small scale production, and in steel vats for industrial level production.