We report on the generation of a 2500 nm bandwidth frequency comb at 6.5 μm central wavelength based on critically phase-matched parametric down-conversion in the nonlinear crystal CdSiP(2) (CSP), driven by a compact Er,Tm:Ho fiber laser. The generated ultra-broadband pulses show a transform-limited duration of 2.3 optical cycles and carry up to 150 pJ of energy at a 100 MHz pulse repetition rate. For comparison, the spectrum generated in AgGaS(2) (AGS) spans from 6.2 to 7.4 μm at full-width at half-maximum (FWHM) with a pulse energy of 3 pJ. A full 3D nonlinear wave propagation code is used for optimization of the noncollinear angle, propagation direction, and crystal thickness.