A non-volatile memory (NVM) cell includes a silicon substrate having a main surface, a source region in a portion of the silicon substrate, a drain region in a portion of the silicon substrate, and a well region disposed in a portion of the silicon substrate between the source and drain regions. The cell includes a bottom oxide layer formed on the main surface of the substrate. The bottom oxide layer is disposed on a portion of the main surface proximate the well region. The cell includes a charge storage layer disposed above the bottom oxide layer, a dielectric tunneling layer disposed above the charge storage layer and a control gate formed above the dielectric tunneling layer. The dielectric tunneling layer includes a first oxide layer, a nitride layer and a second oxide layer. Erasing the NVM cell includes applying a positive gate voltage to inject holes from the gate.