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 September 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

                     September 30, 2000

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

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

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

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

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

     Statements of Cash Flows for the Nine Months Ended
     September 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 ........................................20-29

Part II. OTHER INFORMATION

Item 1. Legal Proceedings......................................30

Item 2. Changes in Securities and Use of Proceeds...........30-32

Item 5. Other Information......................................32

Item 6. Exhibits and Reports on Form 8-K....................33-34




</TABLE>


<PAGE>
<TABLE>
                 PART I.  FINANCIAL INFORMATION

Item 1.  Financial Statements

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

September 30,                         December 31,

2000                                 1999
                                         $                $
                                    (Unaudited)
ASSETS
<S>                                     <C>            <C>
Equity in futures interests trading accounts:
 Cash                               21,889,321     23,430,137

  Net  unrealized  gain  (loss) on open contracts  (MSIL)(78,730)
643,258
  Net  unrealized loss on open contracts (MS &  Co.)    (216,412)
(100,830)

  Total  net unrealized gain (loss) on open contracts   (295,142)
542,428

      Total Trading Equity          21,594,179   23,972,565

                     Subscriptions                     receivable
191,733                                   -   Interest receivable
(MS & Co.)          88,898                             76,192

      Total Assets            21,874,810           24,048,757


LIABILITIES AND PARTNERS' CAPITAL

Liabilities

 Redemptions payable                  412,633       269,545
 Accrued brokerage fees (MS & Co. and MSIL)82,977    70,827
 Accrued management fees (MSCM)         45,096       48,511
          Service          fees         payable         (Demeter)
-                                                    19,404

      Total Liabilities                540,706      408,287

Partners' Capital

 Limited Partners (2,725,496.725 and
    3,062,471.522 Units, respectively)20,999,744 23,310,162
 General Partner (43,395.648 Units)      334,360     330,308

 Total Partners' Capital           21,334,104    23,640,470

  Total  Liabilities and Partners' Capital      21,874,810    24,
048,757


NET ASSET VALUE PER UNIT                  7.70             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.
                    STATEMENT OF OPERATIONS
                           (Unaudited)

<CAPTION>



                              For the Quarters Ended September 30,


                                        2000        1999
                                          $            $
REVENUES
 <S>                                                  <C>   <C>
 Trading profit (loss):
          Realized                               142,2462,955,995
Net change in unrealized               51,554   (214,540)

      Total Trading Results         193,800  2,741,455
    Interest Income (MS & Co.)        263,530     221,516

      Total Revenues                  457,330  2,962,971

EXPENSES

      Brokerage   fees  (MS  &  Co.  and  MSIL)245,853    209,073
Management    fees    (MSCM)                  133,616     143,201
Service                       fees                      (Demeter)
-         57,280

      Total Expenses                  379,469     409,554

NET INCOME                             77,861 2,553,417


NET INCOME ALLOCATION

        Limited     Partners                      76,5182,519,551
General Partner                         1,343   33,866

NET INCOME PER UNIT

       Limited    Partners                       0.03        0.78
General Partner                          0.03     0.78

<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 Nine Months Ended September 30,


2000                                   1999
                                        $              $
REVENUES
 <S>                                        <C>          <C>
 Trading profit (loss):
        Realized                          1,487,013     2,926,692
Net change in unrealized           (837,570)      984,221
      Total Trading Results          649,443  3,910,913
    Interest Income (MS & Co.)       780,748     635,611
      Total Revenues               1,430,191   4,546,524

EXPENSES

    Brokerage fees (MS & Co. and MSIL) 711,010           635,674
      Management   fees   (MSCM)             416,676      435,393
Service fees (Demeter)                58,604     174,157
      Total Expenses               1,186,290   1,245,224

NET INCOME                           243,901   3,301,300


NET INCOME ALLOCATION

       Limited    Partners                   239,849    3,257,557
General Partner                        4,052     43,743

NET INCOME PER UNIT

    Limited Partners                    0.09       1.01
    General Partner                     0.09       1.01

<FN>

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




<PAGE>
<TABLE>
       MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY L.P.
           STATEMENT OF CHANGES IN PARTNERS' CAPITAL
                    For the Nine Months Ended
                   September 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
-                                3,257,557  43,743     3,301,300

Redemptions              (562,772.336)                (3,749,893)
-                    (3,749,893)

Partners' Capital,
  September 30, 1999 3,225,692.364  $24,130,663  $329,060    $24,
459,723





Partners' Capital,
 December 31, 1999  3,105,867.170$23,310,162  $330,308$23,640,470

Offering      of      Units201,296.295                  1,530,081
-                                  1,530,081

Net                                                        Income
-                                    239,849     4,052   243,901
Redemptions              (538,271.092)                (4,080,348)
-                    (4,080,348)

Partners' Capital,
  September 30, 2000  2,768,892.373  $20,999,744  $334,360    $21
,334,104




<FN>








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


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


<CAPTION>

                            For the Nine Months Ended September 30,




2000                                   1999
                                          $            $
CASH FLOWS FROM OPERATING ACTIVITIES
 <S>                                                  <C>   <C>
 Net income                           243,901 3,301,300
 Noncash item included in net income:
    Net change in unrealized          837,570   (984,221)
 (Increase) decrease in operating assets:
   Interest receivable (MS & Co.)   (12,706)    2,259
 Increase (decrease) in operating liabilities:
     Accrued  brokerage  fees (MS  &  Co.  and  MSIL)      12,150
(9,540)
      Accrued   management  fees  (MSCM)      (3,415)     (6,534)
Service fees payable (Demeter)       (19,404)      (2,614)
 Net cash provided by operating activities   1,058,096  2,300,650

CASH FLOWS FROM FINANCING ACTIVITIES

                 Offering                of                 Units
1,530,081                        -
        Increase        in        subscriptions        receivable
(191,733)                        -
 Increase (decrease) in redemptions payable143,088(705,436)
 Redemptions of Units             (4,080,348)   (3,749,893)
  Net  cash  used  for  financing  activities    (2,598,912)    (
4,455,329)

 Net decrease in cash             (1,540,816) (2,154,679)

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

 Balance at end of period          21,889,321  24,365,212


<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  unaudited financial statements contained herein 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  Dean  Witter

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, through March  2000,

paid 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,

2000,  as  amended by SFAS No. 137. The Partnership  adopted  the

provisions  of SFAS No. 133 beginning with the fiscal year  ended

December  31,  1998.  SFAS No. 133 superceded SFAS Nos.  119  and

105,  which  required  the disclosure of average  aggregate  fair

values  and contract/notional values, respectively, of derivative

financial  instruments for an entity that carries its  assets  at

fair  value.  SFAS No. 133 was further amended by SFAS  No.  138,

which  clarifies issues surrounding interest rate  risk,  foreign

currency  denominations,  normal  purchases  and  sales  and  net

hedging.  The application of SFAS No. 133, as amended by SFAS No.

137,  did  not  have  a significant effect on  the  Partnership's

financial  statements, nor will the application of the provisions

of  SFAS  No.  138 have a significant effect on the Partnership's

financial statements.



SFAS  No.  133 defines a derivative as a financial instrument  or

other   contract   that   has  all   three   of   the   following

characteristics:





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


  1)    One  or  more  underlying  notional  amounts  or  payment

     provisions;

2)   Requires no initial net investment or a smaller initial net
investment than would be required relative to changes in market
factors;
3)   Terms require or permit net settlement.
Generally derivatives include futures, forwards, swaps or  option

contracts,   or   other   financial  instruments   with   similar

characteristics such as caps, floors and collars.



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

component  of  "Equity in futures interests trading accounts"  on

the  statements of financial condition and totaled $(295,142) and

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



The  $295,142 net unrealized loss on open contracts at  September

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

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

2001 and April 2000, respectively.



<PAGE>

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




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 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

$21,594,179  and $23,972,565 at September 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 nine months

ended  September 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

<PAGE>

traded  by  the  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 Nine Months Ended September 30, 2000

For  the  quarter  ended  September  30,  2000,  the  Partnership

recorded  total  trading revenues including  interest  income  of

$457,330 and posted an increase in Net Asset Value per Unit.  The

most significant gains of approximately 1.6% were recorded in the

energy  markets  primarily during August from long  positions  in

natural  gas  futures  as  prices moved higher  amid  supply  and

storage  concerns.   Additional gains  were  recorded  from  long

positions in crude oil futures and its related products as prices

increased as ongoing supply concerns outweighed signals from OPEC

kingpin  Saudi  Arabia that it would seek a  suitable  production

increase  to  ease the crunch.  In the metals markets,  gains  of

approximately  0.2% were recorded throughout a  majority  of  the

quarter from long positions in copper futures as prices increased

on  technically based buying and declines in copper supplies.  In

the  livestock markets, gains of approximately 0.1% were recorded

primarily during September from long positions in cattle  futures

as  livestock  prices increased.  In soft commodities,  gains  of

approximately 0.1% were produced primarily during July and



<PAGE>

August  from long cotton futures positions as prices moved higher

amid  fears  that the dryness and heat in Texas would  slash  the

size  of  the  U.S. crop.  These gains were partially  offset  by

losses of approximately 1.1% recorded in the agricultural markets

primarily  during  July from long positions  in  corn  and  wheat

futures  as  prices  declined  on  favorable  U.S.  crop  weather

forecasts.  Total expenses for the three months  ended  September

30,  2000 were $379,469, resulting in net income of $77,861.  The

value of a Unit increased from $7.67 at June 30, 2000 to $7.70 at

September 30, 2000.



For  the  nine  months ended September 30, 2000, the  Partnership

recorded  total  trading revenues including  interest  income  of

$1,430,191  and posted an increase in Net Asset Value  per  Unit.

The  most  significant gains of approximately 12.7% 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.   During   August,

additional gains were recorded from long positions in natural gas

futures  as prices moved higher amid supply and storage concerns.

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



<PAGE>

and  increasing  demand.  These gains were  partially  offset  by

losses  of  approximately 3.4% recorded in the  soft  commodities

markets  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  metals markets, losses of approximately  3.2%

were  incurred  primarily 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.  During mid July,

additional losses were incurred from long gold futures  positions

as  gold  prices  fell  after the Bank of England  announced  the

results of its gold auction, which had concluded at a lower price

than  most dealers expected.  In the agricultural markets, losses

of  approximately 2.9% were recorded primarily during April, June

and  July  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  nine  months  ended

September  30, 2000 were $1,186,290, resulting in net  income  of

$243,901.   The value of a Unit increased from $7.61 at  December

31, 1999 to $7.70 at September 30, 2000.



For the Quarter and Nine Months Ended September 30, 1999

For  the  quarter  ended  September  30,  1999,  the  Partnership

recorded  total  trading revenues including  interest  income  of

$2,962,971 and

<PAGE>

posted   an   increase  in  Net  Asset  Value  per   Unit.    The

Partnership's  long-only  trading  approach  recorded  its   most

significant  gains  of approximately 6.8% in the  metals  markets

primarily  from  long positions in zinc futures  as  zinc  prices

pushed  higher  during August on speculation that consumers  were

under-hedged  and  looking to lock in prices at  current  levels.

Additional  gains  were recorded throughout  a  majority  of  the

quarter  from  long  copper futures positions  as  copper  prices

increased amid improved demand from Asia and a decline in  London

Metal Exchange warehouse stocks.  In the energy markets, gains of

approximately  4.8%  were recorded primarily  from  long  futures

positions in crude oil and its refined products, unleaded gas and

heating  oil,  as  oil prices climbed higher  during  August  and

September due to a perceived tightness in the gasoline market and

an  announcement  by  OPEC  ministers  stating  that  they  would

continue  to adhere to agreed upon output cuts through the  first

quarter   of   2000.    In  the  livestock  markets,   gains   of

approximately 1.5% were recorded primarily from long positions in

feeder  cattle futures as prices increased early  in  July  on  a

decline in corn prices.  During September, additional gains  were

recorded from long positions in feeder and live cattle futures as

cattle prices moved higher due to an increase in cash prices  and

beef  demand.   These gains were partially offset  by  losses  of

approximately 0.7% recorded in the agricultural markets primarily

from  long positions in corn futures as prices dropped  in  early

July  on reports of favorable crop weather in the U.S. corn  belt

and during September amid signs that the crop suffered less

<PAGE>

damage  than  expected from a dry spell just before  the  harvest

began   in   most  states.   In  soft  commodities,   losses   of

approximately  0.7%  were experienced during July  and  September

primarily from long coffee futures positions as prices slid lower

due  to increased supplies, diminishing fears of impending  frost

damage  to  Brazilian  plantations and on predictions  of  record

harvests  in  Brazil  next year.  Total expenses  for  the  three

months  ended September 30, 1999 were $409,554, resulting in  net

income of $2,553,417. The value of a Unit increased from $6.80 at

June 30, 1999 to $7.58 at September 30, 1999.



For  the  nine  months ended September 30, 1999, the  Partnership

recorded  total  trading revenues including  interest  income  of

$4,546,524  and posted an increase in Net Asset Value  per  Unit.

The  most  significant gains of approximately 14.2% were recorded

in  the  energy markets primarily from long futures positions  in

crude oil and its refined products, unleaded gas and heating oil,

as  prices  climbed  higher during March following  an  agreement

reached  by both OPEC and non-OPEC countries to cut total  output

beginning  April  1st.   Oil  prices  continued  to  move  higher

throughout   the   third  quarter  due  to  declining   supplies,

increasing  demand and adherence to the agreed-upon output  cuts.

In  the metals markets, gains of approximately 8.4% were recorded

during  April,  June,  August and September primarily  from  long

positions  in nickel, copper and aluminum futures as  base  metal

prices increased due to strong producer demand, tightening supply

<PAGE>

levels  and reports that several major copper producers would  be

reducing   production.   In  the  livestock  markets,  gains   of

approximately 1.5% were recorded primarily from long positions in

feeder  cattle futures as prices increased early  in  July  on  a

decline in corn prices.  During September, additional gains  were

recorded from long positions in feeder and live cattle futures as

cattle prices moved higher due to an increase in cash prices  and

beef  demand.   These gains were partially offset  by  losses  of

approximately  3.8%  recorded  in the  soft  commodities  markets

primarily  from  long positions in cocoa and  coffee  futures  as

prices  in  these markets declined during the first half  of  the

year  amid fears that economic turmoil in Brazil would lead  them

to  flood the market with increased exports and on forecasts  for

favorable  growing  weather in that  region.   During  the  third

quarter,  losses  were  experienced  from  long  coffee   futures

positions  as  prices  slid  lower  due  to  increased  supplies,

diminishing   fears  of  impending  frost  damage  to   Brazilian

plantations and on predictions of record harvests in Brazil  next

year.  In the agricultural markets, losses of approximately  3.6%

were  recorded primarily from long positions in corn,  wheat  and

soybean futures as grain prices moved lower on concerns regarding

Brazil's economic status, higher-than-expected supply levels  and

on  reports  of favorable crop weather.  Total expenses  for  the

nine  months ended September 30, 1999 were $1,245,224,  resulting

in  net income of $3,301,300.  The value of a Unit increased from

$6.57 at December 31, 1998 to $7.58 at September 30, 1999.

<PAGE>

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

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.

<PAGE>

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-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.



<PAGE>

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

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

<PAGE>

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  table  indicates  the  VaR  associated  with  the

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

by  primary  market risk category as of September  30,  2000  and

1999.  As of September 30, 2000 and 1999, the Partnership's total

capitalization  was approximately $21 million  and  $24  million,

respectively.


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

     Commodity                   (1.71)%              (2.04)%


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

positions  at  September  30, 2000  and  1999  only  and  is  not

necessarily 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.





<PAGE>

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 October

1, 1999 through September 30, 2000.



Primary Market Risk Category        High       Low     Average

Commodity                          (2.10)%    (1.41)%  (1.73)%



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

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,  give

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:



<PAGE>

     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 September 30, 2000

and  for  the  end of the four quarterly reporting  periods  from

October  1, 1999 through September 30, 2000.  Since VaR is  based

on historical 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.



<PAGE>


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 September  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

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

<PAGE>

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 September 30, 2000, by market sector.   It  may

be  anticipated  however, that these market exposures  will  vary

materially over time.



Commodity

Soft  Commodities and Agricultural. On September  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.





<PAGE>

Metals.    The  Partnership's primary metals market  exposure  at

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

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

metals  such  as  copper,  aluminum, zinc  and  nickel,  but  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.



Energy.  On September 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

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 September 30, 2000:



<PAGE>

Foreign  Currency Balances.  The Partnership did not have foreign

currency balances as of September 30, 2000.



Qualitative Disclosures Regarding Means of Managing Risk Exposure

The  Partnership and the Trading Advisor, separately, attempt  to

manage   the   risk  of  the  Partnership's  open  positions   in

essentially  the  same  manner in all market  categories  traded.

Demeter  attempts  to manage market exposure by diversifying  the

Partnership's assets among different market sectors  and  trading

approaches, and monitoring the performance of the Trading Advisor

daily.     In   addition,   the   Trading   Advisor   establishes

diversification  guidelines, often set in terms  of  the  maximum

margin  to be committed to positions in any one market sector  or

market-sensitive instrument.



Demeter monitors and controls the risk of the Partnership's  non-

trading   instrument,  cash.   Cash  is  the   only   Partnership

investment directed by Demeter, rather than the Trading Advisor.

















<PAGE>

                   PART II.  OTHER INFORMATION



Item 1.  LEGAL PROCEEDINGS

Please  refer  to 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.



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

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,



<PAGE>

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.



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

<PAGE>

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  September  30, 2000, 4,396,789.927 total  Units  of  the

Partnership  have been sold, leaving 6,798,703.705 Units  unsold.

The  aggregate price of Units sold through September 30, 2000  is

$42,765,303 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

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

Commencing December 1, 2000 the annual incentive fee rate paid by

the  Partnership to its Trading Advisor will change to  17.5%  of

its trading profits.












<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)

November 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.