The invention relates to scaling a nonvolatile trapped-charge memory device. In an embodiment, scaling includes multiple oxidation and nitridation operations to provide a tunneling layer with a dielectric constant higher than that of a pure silicon dioxide tunneling layer but with a fewer hydrogen and nitrogen traps than a tunneling layer having nitrogen at the substrate interface. In an embodiment, scaling includes forming a charge trapping layer with a non-homogenous oxynitride stoichiometry. In one embodiment the charge trapping layer includes a silicon-rich, oxygen-rich layer and a silicon-rich, oxygen-lean oxynitride layer on the silicon-rich, oxygen-rich layer. In an embodiment, the method for scaling includes a dilute wet oxidation to density a deposited blocking oxide and to oxidize a portion of the silicon-rich, oxygen-lean oxynitride layer.