UNITED STATES
               SECURITIES AND EXCHANGE COMMISSION
                     Washington, D.C. 20549

                           FORM 10-Q



[X]   Quarterly  report pursuant to Section 13 or  15(d)  of  the
Securities Exchange Act of 1934
For the quarterly period ended June 30, 2000 or

[  ]   Transition report pursuant to Section 13 or 15(d)  of  the
Securities Exchange Act of 1934
For the transition period from               to________________

Commission File No. 0-24035

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.

     (Exact name of registrant as specified in its charter)


          Delaware                                13-3968008
State   or  other  jurisdiction  of                       (I.R.S.
Employer
incorporation or organization)                     Identification
No.)


c/o Demeter Management Corporation
Two World Trade Center, 62 Fl., New York, NY             10048
(Address of principal executive offices)               (Zip Code)


Registrant's telephone number, including area code (212) 392-5454



(Former  name, former address, and former fiscal year, if changed
since last report)



Indicate  by check-mark whether the registrant (1) has filed  all
reports  required  to be filed by Section  13  or  15(d)  of  the
Securities  Exchange Act of 1934 during the preceding  12  months
(or  for such shorter period that the registrant was required  to
file  such  reports),  and (2) has been subject  to  such  filing
requirements for the past 90 days.

Yes    X            No___________



<PAGE>
<TABLE>

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.

             INDEX TO QUARTERLY REPORT ON FORM 10-Q

                        June 30, 2000
<CAPTION>

PART I. FINANCIAL INFORMATION
<S>                                                      <C>
Item 1. Financial Statements

     Statements of Financial Condition June 30, 2000
     (Unaudited) and December 31, 1999.................... 2

     Statements of Operations for the Quarters Ended
     June 30, 2000 and 1999 (Unaudited)................... 3

     Statements of Operations for the Six Months Ended
     June 30, 2000 and 1999 (Unaudited)....................4

     Statements of Changes in Partners' Capital for the
        Six Months Ended June 30, 2000 and 1999 (Unaudited)...5

     Statements of Cash Flows for the Six Months Ended
     June 30, 2000 and 1999 (Unaudited)....................6

        Notes to Financial Statements (Unaudited)..........7-11

Item 2. Management's Discussion and Analysis of

Financial Condition and Results of Operations..12-19

Item 3. Quantitative and Qualitative Disclosures about
        Market Risk ...................................19-28

Part II. OTHER INFORMATION

Item 1. Legal Proceedings..............................29-30

Item 2. Changes in Securities and Use of Proceeds......30-33

Item 5. Other Information.................................33

Item 6. Exhibits and Reports on Form 8-K...............34-35

</TABLE>





<PAGE>
<TABLE>


                 PART I.  FINANCIAL INFORMATION

Item 1.  Financial Statements

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
               STATEMENTS OF FINANCIAL CONDITION
<CAPTION>

June 30,                              December 31,

2000                                 1999
                                         $                $
                                    (Unaudited)
ASSETS
<S>                                     <C>                           <C>
Equity in futures interests trading accounts:
 Cash                               22,110,122     23,430,137

  Net  unrealized gain (loss) on open contracts  (MSIL)      (123
,808)                                 643,258
  Net  unrealized loss on open contracts (MS & Co.)     (222,888)
(100,830)

 Total net unrealized gain (loss) on open contracts     (346,696)
542,428

      Total Trading Equity          21,763,426   23,972,565

                     Subscriptions                     receivable
280,364                                     - Interest receivable
(MS      &     Co.)                                        85,599
76,192

      Total Assets               22,129,389        24,048,757


LIABILITIES AND PARTNERS' CAPITAL

Liabilities

 Redemptions payable                  230,907       269,545
 Accrued brokerage fees (MS & Co. and MSIL)83,982    70,827
 Accrued management fees (MSCM)         45,642       48,511
 Service fees payable (Demeter)      ______-__        19,404

      Total Liabilities                360,531      408,287

Partners' Capital

 Limited Partners (2,793,320.622 and
  3,062,471.522 Units, respectively)21,435,841   23,310,162
 General Partner (43,395.648 Units)      333,017     330,308

 Total Partners' Capital           21,768,858    23,640,470

  Total  Liabilities and Partners' Capital     22,129,389    24,0
48,757

NET ASSET VALUE PER UNIT                  7.67             7.61
<FN>
          The accompanying notes are an integral part
                 of these financial statements.
</TABLE>
<PAGE>
<TABLE>
      MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
                    STATEMENTS OF OPERATIONS
                           (Unaudited)



<CAPTION>
                                For the Quarters Ended June 30,

                                        2000        1999
                                          $            $
REVENUES
<S>
<C>                          <C>
 Trading profit (loss):
       Realized                           (50,397)       (64,158)
Net change in unrealized              209,394   402,750

      Total Trading Results           158,997   338,592
    Interest Income (MS & Co.)        260,504    205,500
      Total Revenues                  419,501    544,092
EXPENSES

      Brokerage  fees  (MS  &  Co.  and  MSIL)251,251     211,507
Management    fees   (MSCM)                  136,549      144,867
Service fees (Demeter)              _____-___      57,947

      Total Expenses                  387,800     414,321

NET INCOME                             31,701     129,771


NET INCOME ALLOCATION

       Limited   Partners                     30,818      128,051
General Partner                           883     1,720

NET INCOME PER UNIT

       Limited   Partners                       0.02         0.04
General Partner                          0.02      0.04

<FN>





          The accompanying notes are an integral part
                 of these financial statements.
</TABLE>


<PAGE>
<TABLE>
      MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
                    STATEMENTS OF OPERATIONS
                           (Unaudited)


            <CAPTION>

                               For the Six Months Ended June 30,

                                       2000           1999
                                          $             $
REVENUES
<S>
<C>                             <C>
 Trading profit (loss):
    Realized                       1,344,767     (29,303)
    Net change in unrealized       (889,124)    1,198,761
      Total Trading Results          455,643  1,169,458
    Interest Income (MS & Co.)       517,218      414,095
      Total Revenues                 972,861   1,583,553

EXPENSES

    Brokerage fees (MS & Co. and MSIL) 465,157           426,601
      Management   fees   (MSCM)             283,060      292,192
Service fees (Demeter)                58,604      116,877
      Total Expenses                 806,821      835,670

NET INCOME                           166,040      747,883

NET INCOME ALLOCATION

       Limited   Partners                   163,331       738,006
General Partner                        2,709      9,877

NET INCOME PER UNIT

    Limited Partners                    0.06       0.23
    General Partner                     0.06       0.23



<FN>

          The accompanying notes are an integral part
                 of these financial statements.
</TABLE>


<PAGE>
<TABLE>
       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
           STATEMENTS OF CHANGES IN PARTNERS' CAPITAL
         For the Six Months Ended June 30, 2000 and 1999
                          (Unaudited)


<CAPTION>



Units of

Partnership               Limited   General

Interest                  Partners  Partner    Total



<S>                                                           <C>
<C>                    <C>                  <C>
Partners' Capital,
  December 31, 1998 3,788,464.700  $24,622,999  $285,317    $24,9
08,316

Net                                                        Income
-                       738,006   9,877      747,883

Redemptions           (448,037.865)                   (2,933,341)
-                    (2,933,341)

Partners' Capital,
  June 30, 1999    3,340,426.835   $22,427,664   $295,194     $22
,722,858




Partners' Capital,
  December 31, 19993,105,867.170  $23,310,162  $330,308    $23,64
0,470

Offering      of     Units105,748.916                     803,735
-                                   803,735

Net                                                        Income
-                                  163,331  2,709      166,040

Redemptions           (374,899.816)                   (2,841,387)
-                   (2,841,387)

Partners' Capital,
  June 30, 2000    2,836,716.270   $21,435,841   $333,017     $21
,768,858





<FN>






           The accompanying notes are an integral part
                 of these financial statements.

</TABLE>
<PAGE>
<TABLE>
       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
                    STATEMENTS OF CASH FLOWS
                           (Unaudited)



<CAPTION>
                               For the Six Months Ended June 30,

                                       2000           1999
                                          $             $
CASH FLOWS FROM OPERATING ACTIVITIES
<S>
<C>                           <C>
 Net income                           166,040   747,883
        Noncash item included in net income:
      Net change in unrealized        889,124 (1,198,761)
 (Increase) decrease in operating assets:
   Interest receivable (MS & Co.)    (9,407)    12,353
 Increase (decrease) in operating liabilities:
     Accrued  brokerage  fees (MS  &  Co.  and  MSIL)      13,155
(14,159)
      Accrued  management  fees  (MSCM)     (2,869)       (9,699)
Service fees payable (Demeter)       (19,404)      (3,880)
 Net cash provided by (used for) operating activities   1,036,639
(466,263)

CASH FLOWS FROM FINANCING ACTIVITIES

                 Offering                of                 Units
803,735                                                         -
Increase           in          subscriptions           receivable
(280,364)                          -
    Decrease   in   redemptions   payable       (38,638)(564,797)
Redemptions   of  Units                               (2,841,387)
(2,933,341)

  Net  cash  used  for  financing  activities    (2,356,654)   (3
,498,138)

 Net decrease in cash             (1,320,015) (3,964,401)

 Balance at beginning of period    23,430,137   26,519,891

 Balance at end of period          22,110,122  22,555,490

<FN>




          The accompanying notes are an integral part
                 of these financial statements.

</TABLE>





<PAGE>

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.

                  NOTES TO FINANCIAL STATEMENTS

                           (UNAUDITED)



The  financial statements include, in the opinion of  management,

all  adjustments necessary for a fair presentation of the results

of  operations  and  financial condition of Morgan  Stanley  Dean

Witter   Spectrum   Commodity  L.P.  (the  "Partnership").    The

financial statements and condensed notes herein should be read in

conjunction  with  the  Partnership's December  31,  1999  Annual

Report on Form 10-K.



1. Organization

Morgan  Stanley Dean Witter Spectrum Commodity L.P. is a Delaware

limited  partnership organized to engage primarily in speculative

trading  of  futures contracts in metals, energy and agricultural

markets (collectively, "futures interests").  The Partnership  is

one  of  the Morgan Stanley Dean Witter Spectrum Series of funds,

comprised of the Partnership, Morgan Stanley Dean Witter Spectrum

Global  Balanced L.P., Morgan Stanley Dean Witter Spectrum Select

L.P.,  Morgan Stanley Dean Witter Spectrum Strategic L.P., Morgan

Stanley  Dean Witter Spectrum Technical L.P., and Morgan  Stanley

Dean  Witter Spectrum Currency L.P. (collectively, the  "Spectrum

Series").    The   Partnership's  general  partner   is   Demeter

Management  Corporation ("Demeter").  The commodity  brokers  are

Morgan Stanley & Co. Incorporated ("MS & Co.") and Morgan Stanley

& Co.

<PAGE>

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)


International  Limited  ("MSIL"), (collectively,  the  "Commodity

Brokers").   The  trading advisor is Morgan  Stanley  Commodities

Management,  Inc. ("MSCM" or the "Trading Advisor").   MSCM,  the

Commodity  Brokers and Demeter are all wholly-owned  subsidiaries

of Morgan Stanley Dean Witter & Co.



2.  Related Party Transactions

The  Partnership's cash is on deposit with the Commodity  Brokers

in futures interests trading accounts to meet margin requirements

as  needed.  MS  & Co. pays interest on these funds  based  on  a

prevailing  rate  on  U.S. Treasury bills. The  Partnership  pays

brokerage  fees  to  the Commodity Brokers, management  fees  and

incentive  fees  (if  applicable) to MSCM, and  service  fees  to

Demeter.

3.  Financial Instruments

The  Partnership trades futures interests in metals,  energy  and

agricultural markets.  Futures interests represent contracts  for

delayed delivery of an instrument at a specified date and  price.

Risk arises from changes in the value of these contracts and  the

potential inability of counterparties to perform under the  terms

of   the  contracts.   There  are  numerous  factors  which   may

significantly  influence  the market value  of  these  contracts,

including interest rate volatility.



<PAGE>

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)


In  June  1998, the Financial Accounting Standards Board ("FASB")

issued  Statement of Financial Accounting Standard  ("SFAS")  No.

133,   "Accounting   for  Derivative  Instruments   and   Hedging

Activities" effective for fiscal years beginning after  June  15,

1999.   In  June 1999, the FASB issued SFAS No. 137,  "Accounting

for  Derivative Instruments and Hedging Activities - Deferral  of

the  Effective Date of SFAS No. 133," which defers  the  required

implementation of SFAS No. 133 until fiscal years beginning after

June  15, 2000.  However, the Partnership had previously  elected

to adopt the provisions of SFAS No. 133 beginning with the fiscal

year  that ended December 31, 1998.  SFAS No. 133 supersedes SFAS

No.  119  and No. 105, which required the disclosure  of  average

aggregate fair values and contract/notional values, respectively,

of  derivative financial instruments for an entity which  carries

its  assets at fair value.  The application of SFAS No. 133  does

not  have  a  significant  effect on the Partnership's  financial

statements.



The net unrealized gain (loss) on open contracts are reported  as

a  component of "Equity in futures interests trading accounts" on

the  statements of financial condition and totaled $(346,696) and

$542,428 at June 30, 2000 and December 31, 1999, respectively.





<PAGE>
       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)


The  $346,696 net unrealized loss on open contracts at  June  30,

2000  and  the $542,428 net unrealized gain on open contracts  at

December  31,  1999  were  related  to  exchange-traded   futures

contracts.



Exchange-traded futures contracts held by the Partnership at June

30,  2000 and December 31, 1999 mature through December 2000  and

April 2000, respectively.



The Partnership has credit risk associated with counterparty non-

performance.  The credit risk associated with the instruments  in

which  the  Partnership  is involved is limited  to  the  amounts

reflected in the Partnership's statements of financial condition.



The  Partnership also has credit risk because MS & Co.  and  MSIL

act  as  the  futures commission merchants or the  counterparties

with  respect  to  most of the Partnership's  assets.   Exchange-

traded  futures contracts are marked to market on a daily  basis,

with variations in value settled on a daily basis.  Each of MS  &

Co.   and  MSIL,  as  a  futures  commission  merchant  for   the

Partnership's  exchange-traded futures contracts,  are  required,

pursuant   to  regulations  of  the  Commodity  Futures   Trading

Commission ("CFTC"), to segregate from their own assets, and  for

the sole benefit of their commodity customers, all funds held  by

them with respect to

<PAGE>

       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
            NOTES TO FINANCIAL STATEMENTS (CONCLUDED)




exchange-traded futures contracts, including an amount  equal  to

the  net  unrealized  gain (loss) on all open futures  contracts,

which   funds,   in   the  aggregate,  totaled  $21,763,426   and

$23,972,565 at June 30, 2000 and December 31, 1999, respectively.






































<PAGE>
Item   2.  MANAGEMENT'S  DISCUSSION  AND  ANALYSIS  OF  FINANCIAL
CONDITION AND RESULTS OF OPERATIONS



Liquidity  -   The  Partnership  deposits  its  assets  with  the

Commodity   Brokers   in   separate  futures   trading   accounts

established  for the Trading Advisor, which assets  are  used  as

margin  to engage in trading. The assets are held in either  non-

interest  bearing bank accounts or in securities and  instruments

permitted  by  the CFTC for investment of customer segregated  or

secured  funds.  The Partnership's assets held by  the  Commodity

Brokers  may  be  used  as margin solely  for  the  Partnership's

trading.   Since the Partnership's sole purpose is  to  trade  in

futures  and  forwards, it is expected that the Partnership  will

continue to own such liquid assets for margin purposes.



The  Partnership's investment in futures and forwards  may,  from

time  to  time,  be illiquid.  Most U.S. futures exchanges  limit

fluctuations  in  prices  during  a  single  day  by  regulations

referred  to  as  "daily  price fluctuations  limits"  or  "daily

limits".   Trades may not be executed at prices beyond the  daily

limit.   If  the  price  for a particular  futures  contract  has

increased  or  decreased by an amount equal to the  daily  limit,

positions  in  that  futures contract can neither  be  taken  nor

liquidated  unless  traders are willing to effect  trades  at  or

within  the  limit.  Futures prices have occasionally  moved  the

daily limit for several consecutive





<PAGE>

days  with  little or no trading.  These market conditions  could

prevent  the  Partnership from promptly liquidating  its  futures

contracts and result in restrictions on redemptions.



The  Partnership  has  never had illiquidity  affect  a  material

portion of its assets.



Capital  Resources. The Partnership does not have, or  expect  to

have,  any capital assets.  Redemptions, exchanges and  sales  of

additional  units of limited partnership interest ("Unit(s)")  in

the  future  will  affect  the  amount  of  funds  available  for

investment in futures interests in subsequent periods.  It is not

possible  to  estimate the amount, and therefore, the  impact  of

future redemptions of Units.



Results of Operations

General.  The Partnership's results depend on its Trading Advisor

and  the ability of the Trading Advisor's trading program to take

advantage of price movements or other profit opportunities in the

futures  and forwards markets.  The following presents a  summary

of  the  Partnership's operations for the quarter and six  months

ended  June  30,  2000  and  1999, respectively,  and  a  general

discussion of its trading activities during each period.   It  is

important  to note, however, that the Trading Advisor  trades  in

various markets at different times and that prior activity  in  a

particular market does not mean that such market will be actively

traded by the

<PAGE>

Trading   Advisor   or  will  be  profitable   in   the   future.

Consequently,  the results of operations of the  Partnership  are

difficult  to  discuss other than in the context of  its  Trading

Advisor's  trading activities on behalf of the Partnership  as  a

whole and how the Partnership has performed in the past.



For the Quarter and Six Months Ended June 30, 2000

For  the  quarter  ended June 30, 2000, the Partnership  recorded

total trading revenues including interest income of $419,501  and

posted  an  increase  in  Net Asset  Value  per  Unit.  The  most

significant  gains of approximately 6.4% were recorded  primarily

during  May in the energy markets from long positions in  natural

gas  futures  as  prices continued their upward  trend,  as  data

released by the American Gas Association further confirmed  fears

that inventory levels remain low.  Adding to supply concerns were

fears  that the U.S. demand will outstrip production this summer,

when   inventories  are  typically  refilled  for   the   winter.

Additional  gains  were recorded during May and  June  from  long

futures  positions in crude oil and its related products  as  the

previous  upward  movement in oil prices re-emerged  amid  rising

concerns  regarding supplies and production levels.  These  gains

were  partially offset by losses of approximately  4.2%  recorded

primarily during April and June in the agricultural markets  from

long  positions in corn futures as prices dropped  due  to  heavy

rain and cooler temperatures in the major corn producing regions.

In soft commodities, losses of approximately 0.9% were

<PAGE>

experienced throughout a majority of the quarter from long coffee

futures  positions  as  prices decreased  on  technical  factors.

Additional  losses were experienced during June from long  cotton

futures  positions as prices moved lower, pressured  downward  by

heavy  deliveries in July, benign weather forecasts for the  U.S.

cotton  belt  and expectations that crop size was edging  higher.

In the metals markets, losses of approximately 0.4% were incurred

primarily  during May and June from long nickel futures positions

as  prices  moved  lower.   Total expenses for the  three  months

ended  June  30, 2000 were $387,800, resulting in net  income  of

$31,701.   The value of a Unit increased from $7.65 at March  31,

2000 to $7.67 at June 30, 2000.



For  the six months ended June 30, 2000, the Partnership recorded

total trading revenues including interest income of $972,861  and

posted  an  increase  in  Net Asset Value  per  Unit.   The  most

significant  gains of approximately 10.9% were  recorded  in  the

energy  markets  primarily  during May  from  long  positions  in

natural  gas futures as prices continued their upward  trend,  as

data  released by the American Gas Association further  confirmed

fears  that  inventory levels remain low.  Additional gains  were

recorded  during January and February from long futures positions

in  crude oil and its refined products as oil prices increased on

concerns  about  future output levels from  the  world's  leading

producer  countries  amid  dwindling  stockpiles  and  increasing

demand.  These gains were partially offset by losses of

<PAGE>

approximately 3.4% incurred in the metals markets primarily  from

long  aluminum  and copper futures positions as  prices  reversed

lower  earlier  in  February due primarily to  technically  based

selling.   Losses were also recorded during March from long  gold

futures  positions as gold prices fell on fears that  the  French

central bank could decide to sell some of its reserves.  In  soft

commodities, losses of approximately 3.3% were recorded primarily

during January and February from long coffee futures positions as

coffee prices declined in the wake of forecasts for a bumper crop

in Brazil.  Additional losses were recorded throughout a majority

of  the  second  quarter from long coffee  futures  positions  as

prices  decreased  on  technical factors.   In  the  agricultural

markets,  losses  of  approximately 1.8% were recorded  primarily

during  April  and June from long positions in  corn  futures  as

prices  dropped due to heavy rain and cooler temperatures in  the

major  corn producing regions.  Total expenses for the six months

ended  June  30, 2000 were $806,821, resulting in net  income  of

$166,040.   The value of a Unit increased from $7.61 at  December

31, 1999 to $7.67 at June 30, 2000.



For the Quarter and Six Months Ended June 30, 1999

For  the  quarter  ended June 30, 1999, the Partnership  recorded

total trading revenues including interest income of $544,092  and

posted an increase in Net Asset Value per Unit. The Partnership's

long-only trading approach recorded its most significant gains of

approximately 2.7% in the metals markets primarily from long

<PAGE>

positions  in  base metal futures as nickel, copper and  aluminum

prices  increased during April and June.  The rise in base  metal

prices   was  largely  attributed  to  strong  producer   demand,

tightening  supply levels and reports that several  major  copper

producers would be reducing production.  Gains were also recorded

in  this  market  complex from long silver futures  positions  as

silver  prices  also  moved higher during  April  and  June  amid

technically-driven  buying spurred by the rally  in  base  metals

prices, a decline in U.S. market reserves and the announcement of

a   cutback   in   metal  production.   Additional   profits   of

approximately 2.3% were recorded in the energy markets  primarily

during  April and June from long positions in crude  and  heating

oil  futures  as  oil  prices rose on  signs  of  better  demand,

particularly from Asia, a decline in inventory levels  and  signs

that  OPEC member states were respecting output cuts.  A  portion

of  the Partnership's overall gains for the quarter was offset by

losses  of  approximately 2.1% experienced  in  the  agricultural

markets  primarily from long positions in wheat futures positions

as  prices  declined  on  a  USDA report of  higher-than-expected

supply  levels and slumping U.S. exports.  Additional  losses  of

approximately 0.9% were recorded in the soft commodities  markets

primarily  from  long coffee futures positions  as  prices  moved

lower  during April and June on forecasts for warmer temperatures

in  Brazil.  Losses were also experienced from long positions  in

cocoa  futures during April and May, as well as from long  cotton

futures  positions during May and June. Total  expenses  for  the

three months ended

<PAGE>

June 30, 1999 were $414,321, resulting in net income of $129,771.

The  value  of a Unit increased from $6.76 at March 31,  1999  to

$6.80 at June 30, 1999.



For  the six months ended June 30, 1999, the Partnership recorded

total  trading  revenues including interest income of  $1,583,553

and  posted  an  increase in Net Asset Value per Unit.  The  most

significant  gains  of approximately 9.5% were  recorded  in  the

energy markets primarily from long futures positions in crude oil

and  its refined products, heating oil and unleaded gasoline,  as

oil  prices  moved  considerably higher during March,  April  and

June.  The substantial recovery in oil prices during these months

was  largely  attributed to the news of a  decline  in  inventory

levels  that resulted from an agreement reached by both OPEC  and

non-OPEC  countries  to  cut total output.  Additional  gains  of

approximately 1.5% were recorded in the metals markets  primarily

during  the second quarter from long positions in nickel,  copper

and  aluminum futures as base metal prices increased during April

and  June due to strong producer demand, tightening supply levels

and reports that several major copper producers would be reducing

production. A portion of the Partnership's overall gains for  the

year  were offset by losses of approximately 3.1% experienced  in

the  soft  commodities markets primarily from long  positions  in

cocoa  and  coffee  futures as prices in these  markets  declined

throughout  most of the year amid fears that economic turmoil  in

Brazil would lead them to flood the market with increased exports

<PAGE>

and  on  forecasts for favorable growing weather in that  region.

Losses   of  approximately  2.9%  were  also  recorded   in   the

agricultural  markets  primarily from long  positions  in  wheat,

soybean oil, soybean and corn futures as grain prices moved lower

on  concerns  regarding Brazil's economic status and higher-than-

expected supply levels.  Total expenses for the six months  ended

June 30, 1999 were $835,670, resulting in net income of $747,883.

The value of a Unit increased from $6.57 at December 31, 1998  to

$6.80 at June 30, 1999.


Item 3. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET
        RISK

Introduction

The  Partnership is a commodity pool involved in the  speculative

trading  of  futures interests.  The market-sensitive instruments

held  by  the  Partnership are acquired  solely  for  speculative

trading purposes only and, as a result, all or substantially  all

of  the Partnership's assets are at risk of trading loss.  Unlike

an operating company, the risk of market-sensitive instruments is

central,  not  incidental,  to  the Partnership's  main  business

activities.



The  futures interests traded by the Partnership involve  varying

degrees  of  market  risk.  Market risk is often  dependent  upon

changes  in  the level or volatility of interest rates,  exchange

rates,  and  prices  of  financial instruments  and  commodities.

Fluctuations in market risk based upon these factors result in

<PAGE>

frequent  changes  in  the fair value of the  Partnership's  open

positions, and, consequently, in its earnings and cash flow.



The  Partnership's  total market risk is  influenced  by  a  wide

variety  of  factors,  including the  diversification  among  the

Partnership's open positions, the volatility present  within  the

markets,  and the liquidity of the markets.  At different  times,

each  of these factors may act to increase or decrease the market

risk associated with the Partnership.



The  Partnership's past performance is not necessarily indicative

of  its future results.  Any attempt to numerically quantify  the

Partnership's  market risk is limited by the uncertainty  of  its

speculative  trading.  The Partnership's speculative trading  may

cause future losses and volatility (i.e. "risk of ruin") that far

exceed  the  Partnership's experiences to date or any  reasonable

expectations based upon historical changes in market value.


Quantifying the Partnership's Trading Value at Risk

The    following    quantitative   disclosures   regarding    the

Partnership's  market  risk  exposures  contain  "forward-looking

statements"  within  the meaning of the safe  harbor  from  civil

liability  provided for such statements by the Private Securities

Litigation  Reform Act of 1995 (set forth in Section 27A  of  the

Securities Act of 1933 and Section 21E of the Securities Exchange

Act  of  1934). All quantitative disclosures in this section  are

deemed to be forward-

<PAGE>

looking  statements for purposes of the safe harbor,  except  for

statements of historical fact.



The  Partnership accounts for open positions using mark-to-market

accounting  principles.   Any loss in the  market  value  of  the

Partnership's  open  positions  is  directly  reflected  in   the

Partnership's earnings, whether realized or unrealized, and  cash

flow.   Profits and losses on open positions of exchange  traded-

futures interests are settled daily through variation margin.



The  Partnership's risk exposure in the market sectors traded  by

the  Trading Advisor is estimated below in terms of Value at Risk

("VaR").  The  VaR  model used by the Partnership  includes  many

variables that could change the market value of the Partnership's

trading  portfolio.  The Partnership estimates VaR using a  model

based upon historical simulation with a confidence level of  99%.

Historical  simulation involves constructing  a  distribution  of

hypothetical  daily changes in the value of a trading  portfolio.

The  VaR  model takes into account linear exposures to price  and

interest  rate risk.  Market risks that are incorporated  in  the

VaR  model  include equity and commodity prices, interest  rates,

foreign exchange rates, and correlation among these variables.

The  hypothetical changes in portfolio value are based  on  daily

percentage changes observed in key market indices or other market

factors ("market risk factors") to which the portfolio is



<PAGE>

sensitive.    The   historical   observation   period   of    the

Partnership's VaR is approximately four years.  The  one-day  99%

confidence  level  of the Partnership's VaR  corresponds  to  the

negative change in portfolio value that, based on observed market

risk factors, would have been exceeded once in 100 trading days.



VaR   models,   including  the  Partnership's,  are  continuously

evolving  as trading portfolios become more diverse and  modeling

techniques  and systems capabilities improve.  Please  note  that

the  VaR  model is used to numerically quantify market  risk  for

historic  reporting purposes only and is not utilized  by  either

Demeter  or  the  Trading Advisor in their daily risk  management

activities.



The Partnership's Value at Risk in Different Market Sectors

The  following  tables  indicates the  VaR  associated  with  the

Partnership's open positions as a percentage of total Net  Assets

by  primary market risk category as of June 30, 2000 and 1999. As

of June 30, 2000 and 1999, the Partnership's total capitalization

was approximately $22 million and $23 million, respectively.


     Primary Market           June 30, 2000       June 30, 1999
     Risk Category             Value at Risk      Value at Risk

     Commodity                     (1.70)%            (1.87)%


The  table  above  represents the VaR of the  Partnership's  open

positions at June 30, 2000 and 1999 only and is not necessarily

<PAGE>

representative  of  either the historic  or  future  risk  of  an

investment  in  the  Partnership. Because the Partnership's  only

business  is  the speculative trading of futures  interests,  the

composition  of  its  trading portfolio can change  significantly

over  any given time period, or even within a single trading day.

Any  changes  in  open positions could positively  or  negatively

materially impact market risk as measured by VaR.



The table below supplements the quarter-end VaR by presenting the

Partnership's high, low and average VaR, as a percentage of total

Net Assets for the four quarterly reporting periods from July  1,

1999 through June 30, 2000.



Primary Market Risk Category        High       Low     Average

Commodity                          (2.10)%    (1.70)%   (1.86)%



Limitations on Value at Risk as an Assessment of Market Risk

The  face  value  of the market sector instruments  held  by  the

Partnership  is  typically  many  times  the  applicable   margin

requirements.  Margin requirements generally range between 2% and

15%  of  contract face value. Additionally, the use  of  leverage

causes  the face value of the market sector instruments  held  by

the   Partnership   to  typically  be  many   times   the   total

capitalization   of   the  Partnership.    The   value   of   the

Partnership's open positions thus creates a "risk  of  ruin"  not

typically found in other investments.  The relative size of the

<PAGE>

positions held may cause the Partnership to incur losses  greatly

in excess of VaR within a short period of time, given the effects

of  the  leverage employed and market volatility.  The VaR tables

above, as well as the past performance of the Partnership,  gives

no  indication  of  such "risk of ruin". In  addition,  VaR  risk

measures   should  be  viewed  in  light  of  the   methodology's

limitations, which include the following:

     past  changes in market risk factors will not always result

  in accurate predictions of the distributions and correlations of

  future market movements;

     changes  in portfolio value in response to market movements

  may differ from those of the VaR model;

    VaR results reflect past trading positions while future risk

  depends on future positions;

     VaR using a one-day time horizon does not fully capture the

  market  risk of positions that cannot be liquidated  or  hedged

  within one day; and

     the  historical  market  risk  factor  data  used  for  VaR

  estimation  may provide only limited insight into  losses  that

  could be incurred under certain unusual market movements.



The VaR tables above present the results of the Partnership's VaR

for  the Partnership's market risk exposure at June 30, 2000  and

for the end of the four quarterly reporting periods from July  1,

1999 through June 30, 2000.  Since VaR is based on historical

<PAGE>

data, VaR should not be viewed as predictive of the Partnership's

future  financial performance or its ability to manage or monitor

risk.   There  can be no assurance that the Partnership's  actual

losses  on  a  particular  day will not exceed  the  VaR  amounts

indicated above or that such losses will not occur more than 1 in

100 trading days.



Non-Trading Risk

The  Partnership has non-trading market risk on its foreign  cash

balances  not needed for margin.  These balances and  any  market

risk  they  may represent are immaterial.  At June 30,  2000  the

Partnership's cash balance at MS & Co. was approximately  94%  of

its  total  Net  Asset  Value.  A decline in short-term  interest

rates  will  result  in  a  decline  in  the  Partnership's  cash

management   income.  This  cash  flow  risk  is  not  considered

material.



Materiality,  as used throughout this section,  is  based  on  an

assessment  of  reasonably  possible  market  movements  and  any

associated  potential losses, taking into account  the  leverage,

optionality and multiplier features of the Partnership's  market-

sensitive instruments.



Qualitative Disclosures Regarding Primary Trading Risk Exposures

The following qualitative disclosures regarding the Partnership's

market risk exposures - except for (A) those disclosures that are

<PAGE>

statements of historical fact and (B) the descriptions of how the

Partnership   manages  its  primary  market  risk   exposures   -

constitute  forward-looking  statements  within  the  meaning  of

Section  27A  of  the  Securities Act  and  Section  21E  of  the

Securities  Exchange Act.  The Partnership's primary market  risk

exposures  as  well  as the strategies used and  to  be  used  by

Demeter  and the Trading Advisor for managing such exposures  are

subject  to numerous uncertainties, contingencies and risks,  any

one  of which could cause the actual results of the Partnership's

risk  controls to differ materially from the objectives  of  such

strategies.   Government  interventions,  defaults   and   expro-

priations,   illiquid   markets,  the   emergence   of   dominant

fundamental  factors, political upheavals, changes in  historical

price  relationships,  an  influx  of  new  market  participants,

increased  regulation  and many other  factors  could  result  in

material  losses  as  well as in material  changes  to  the  risk

exposures  and the risk management strategies of the Partnership.

Investors  must be prepared to lose all or substantially  all  of

their investment in the Partnership.



The  following  were the primary trading risk  exposures  of  the

Partnership  as  of June 30, 2000 by market sector.   It  may  be

anticipated  however,  that  these  market  exposures  will  vary

materially over time.





<PAGE>

Commodity.

Soft  Commodities  and  Agriculturals.  On  June  30,  2000,  the

Partnership had exposure in the corn, coffee, wheat  and  in  the

livestock  markets.   Supply  and  demand  inequalities,   severe

weather disruption and market expectations affect price movements

in these markets.



Metals.    The  Partnership's primary metals market  exposure  at

June  30,  2000  was  to fluctuations in the price  of  gold  and

silver.   The  Partnership will, from time to  time,  trade  base

metals  such  as aluminum, copper, zinc and nickel,  however  the

principal  market exposures of the Partnership have  consistently

been  in  precious metals, gold and silver and, to a much  lesser

extent,  platinum.  Gold and silver prices have remained volatile

and  the  Trading Advisor has, from time to time, taken positions

as market opportunities developed.  Demeter anticipates that gold

and silver will remain the primary metals market exposure for the

Partnership.



Energy.  On June 30, 2000, the Partnership's energy exposure  was

shared  primarily  by  futures contracts in  the  crude  oil  and

natural gas markets.  Price movements in these markets result

from political developments in the Middle East, weather patterns,

and  other economic fundamentals.  It is possible that volatility

will  remain  high.  Significant profits and losses,  which  have

been experienced in the past, are expected to continue to be

<PAGE>

experienced in this market.  Natural gas has exhibited volatility

in  prices resulting from weather patterns and supply and  demand

factors and may continue in this choppy pattern.



Qualitative Disclosures Regarding Non-Trading Risk Exposure

The  following  was  the only non-trading risk  exposure  of  the

Partnership as of June 30, 2000:



Foreign Currency Balances

The  Partnership does not have foreign currency  balances  as  of

June 30, 2000.

































<PAGE>

                   PART II.  OTHER INFORMATION



Item 1.  LEGAL PROCEEDINGS

The  following supplements Legal Proceedings previously disclosed

in  the  Partnership's Form 10-Q for the quarter ended March  31,

2000 and Form 10-K for the year ended December 31, 1999:



On  October  25,  1996,  the Market Surveillance  Committee  (the

"Committee")  of  the National Association of Securities  Dealers

("NASD")  filed  a formal complaint against MS &  Co.  and  seven

current  and former traders, alleging violations of certain  NASD

rules  relating  to manipulative and deceptive practices,  locked

and  crossed  markets, and failure to supervise.   Hearings  were

held  in  June  and July 1997.  On April 13, 1998  the  Committee

ruled  that  MS  &  Co.  and the seven  traders  had  engaged  in

manipulative  and  deceptive practices and improperly  locked  or

crossed  markets, but not that MS & Co. had failed  to  supervise

its  traders.  The Committee levied a fine of $1,000,000 on MS  &

Co.,  a  fine of $100,000 and a 90-day suspension on one  of  its

former  traders, and fines of $25,000 and 30-day  suspensions  on

each of the remaining current and former traders.  On January 18,

2000  the National Adjudicatory Council, which heard the  appeal,

issued a ruling which upheld the Committee's April 1998 decision,

however,  the  National Adjudicatory Council reduced  the  firm's

fine to $495,000,





<PAGE>

reversed  all previously imposed suspensions against the traders,

reduced  the fine for each of six traders to $2,500 and dismissed

all charges against the seventh trader.



On  January  11,  1999,  the Securities and  Exchange  Commission

brought an action against 28 NASDAQ market makers, including MS &

Co.,  and  51 individuals, including one current and  one  former

trader  employed  by MS & Co., for certain conduct  during  1994.

The  core  of  the charges against MS & Co. concerns improper  or

undisclosed  coordination  of price  quotes  with  other  broker-

dealers  and  related  reporting, recordkeeping  and  supervisory

deficiencies  in violation of Sections 15(b)(4)(E), 15(c)(1)  and

(2)  and  17(a) of the Securities Exchange Act and Rules  15c1-2,

15c2-7  and  17a-3 promulgated thereunder.  Without admitting  or

denying  the charges, MS & Co. consented to the entry of a  cease

and  desist  order  and  to the payment of  a  civil  penalty  of

$350,000,  disgorgement of $4,170 and to submit  certain  of  its

procedures to an independent consultant for review.  In addition,

one  current and one former trader employed by MS & Co.  accepted

suspensions  of less than two months each and were fined  $25,000

and $30,000 respectively.



Item 2. CHANGE IN SECURITIES AND USE OF PROCEEDS

The   Partnership  registered  5,000,000  Units  pursuant  to   a

Registration  Statement on Form S-1, which  became  effective  on

November 10, 1997 (the "Registration Statement") (SEC File Number

<PAGE>

333-33975).  The Partnership, Demeter, MSCW and DWR extended  the

offering period for unsold Units until no later than October  16,

1998   pursuant  to  Post  Effective  Amendment  No.  1  to   the

Registration Statement, which became effective on July 10, 1998.



The managing underwriter for the Partnership is DWR.



The  offering  originally commenced on  November  10,  1997  with

5,000,000  Units registered and 4,045,503.483 Units sold  through

April  1,  1998.   The  aggregate price of  the  offering  amount

registered was $50,000,000 (based upon the initial offering price

of  $10.00 per Unit) for the initial closing on January  2,  1998

(the "Initial Offering").  After the Initial Offering, Units were

sold  at three closings held on February 2, March 2 and April  1,

1998, at a price equal to 100% of the Net Asset Value per Unit at

the  close  of business on the last day of the month  immediately

preceding the closing.  The aggregate price of the Units sold  at

the four closings of the offering was $40,100,218 (based upon the

Net Asset Value per Unit of $10.00 at January 2, 1998, $10.13  at

February  2, 1998, $9.53 at March 2, 1998 and $9.54 at  April  1,

1998 closings, respectively).



An additional 149,990.149 Units were sold at subsequent closings;

held  on  August 3, September 1 and October 1, 1998  at  a  price

equal  to  100% of the Net Asset Value per Unit at the  close  of

business  on the last day of the month immediately preceding  the

closing.

<PAGE>

The aggregate offering price of the three subsequent closings was

$1,135,005 (based upon the Net Asset Value per Unit of  $7.85  at

August  3, 1998, $7.23 on September 1, 1998 and $7.75 on  October

1, 1998, respectively).



Subsequent  to  these closings, remaining unsold Units  were  de-

registered.



In conjunction with becoming part of the Spectrum Series on March

7, 2000, the Partnership registered an additional 7,000,000 Units

pursuant  to  another Registration Statement on form  S-1,  which

became effective on March 6, 2000 (SEC File Number 33-90483).  As

part  of  the Spectrum Series, Units of the Partnership  are  now

sold  monthly on a continuous basis at a price equal to  100%  of

the Net Asset Value per Unit at the close of business on the last

day of each month.



Through  June  30,  2000,  4,301,242.548  total  Units   of   the

Partnership have been sold, leaving 6,894,251.084 Units unsold as

of June 30, 2000.  The aggregate price of Units sold through June

30, 2000 is $42,038,958 at a price equal to 100% of the Net Asset

Value  per Unit at the close of business on the last day of  each

month.



Since  no expenses are chargeable against proceeds, 100%  of  the

proceeds of the offering have been applied to the working capital

<PAGE>

of  the  Partnership for use in accordance with  the  "Investment

Program,  Use  of Proceeds and Trading Policies" section  of  the

prospectus  included as part of the above referenced Registration

Statement.



Item 5.   OTHER INFORMATION

Effective July 1, 2000, Lewis A. Raibley, III resigned  as  Chief

Financial  Officer  and  a Director of Demeter  and  Dean  Witter

Futures  Currency  Management  Inc.   Effective  July  10,  2000,

Raymond E. Koch replaced Lewis A. Raibley, III as Chief Financial

Officer of Demeter.

































<PAGE>

Item 6.   Exhibits and Reports on Form 8-K

(A)   Exhibits

3.01  Form of Amended and Restated Limited Partnership Agreement
      of  the  Partnership,  is  incorporated  by  reference  to
      Exhibit A of the Partnership's Prospectus, dated March  6,
      2000,  filed  with the Securities and Exchange  Commission
      pursuant  to  Rule 424(b)(3) under the Securities  Act  of
      1933, as amended, on March 9, 2000.

3.02  Certificate of Limited Partnership, dated July 31, 1997, is
     incorporated   by   reference  to  Exhibit   3.02   of   the
     Partnership's Registration Statement on Form S-1 (File No.  333-
     33975)    filed    with   the   Securities   and    Exchange
     commission on August 20, 1997.

3.03   Form  of  Amendment in Certificate of Limited Partnership,
dated  as  of  March  7,  2000 is incorporated  by  reference  to
Exhibit  3.1  of  the  Partnership's  Form  8-K  (File   No.   0-
24035),   filed  with  the  Securities  and  Exchange  Commission
on March 23, 2000.

10.01 Management Agreement, dated as of December 31, 1997,  among
      the   Partnership,  Demeter  Management  Corporation,   and
      Morgan  Stanley Commodities Management Inc. is incorporated
      by reference to exhibit 10.01 of the Partnership's Form 10-
      K  (File  No.  0-24035) for fiscal year ended December  31,
      1998.

10.02       Commodity  Futures Customer Agreement,  dated  as  of
     December  31, 1997., between Morgan Stanley & Co.  Incorporated
     and   the Partnership is incorporated by reference to Exhibit
     10.02 of the Partnership's Form 10-K (File No. 0-24035)  for
     fiscal year ended December 31, 1998.
10.03      Customer Agreement, dated as of December 31, 1997,
among    the Partnership, Morgan Stanley & Co. International
Limited and Morgan Stanley & Co. Incorporated is
incorporated by reference to Exhibit 10.03 of the
Partnership's Form 10-K (File NO. 0-24035) for fiscal year  ended
December 31, 1998.
10.04      Subscription and Exchange Agreement and Power of
Attorney   to be executed by each purchaser of Units is
incorporated   by reference to Annex A of the Partnership's
Supplement to  the Prospectus, dated March 6, 2000, filed with
the         Securities and Exchange Commission pursuant to Rule
424(b)(3) under the Securities Act of 1933, as amended, on  March
9, 2000.





<PAGE>



10.05       Escrow  Agreement, dated October 14, 1998, among  the
     Partnership, Dean Witter Reynolds Inc., and Chemical Bank   is
     incorporated   by  reference  to  Exhibit   10.05   of   the
     Partnership's Form 10-K (File No. 0-24035) for fiscal year  ended
     December 31, 1998.

 (B)  Reports on Form 8-K. - None.




















































<PAGE>






                            SIGNATURE



Pursuant  to  the  requirements of the Securities Exchange  Act  of
1934,  the  Registrant has duly caused this report to be signed  on
its behalf by the undersigned, thereunto duly authorized.




                         Morgan Stanley Dean Witter Spectrum
                          Commodity Fund L.P. (Registrant)

                        By:   Demeter Management Corporation
                              (General Partner)

August 14, 2000         By:/s/Raymond E. Koch_____________________
                              Raymond E. Koch
                              Chief Financial Officer




The  General  Partner  which signed the above  is  the  only  party
authorized  to  act  for  the Registrant.  The  Registrant  has  no
principal   executive   officer,   principal   financial   officer,
controller,  or principal accounting officer and has  no  Board  of
Directors.