The present invention relates to a flash EEPROM cell using polysilicon-to-polysilicon hot electron emission to erase the memory contents of the cell. Exemplary embodiments include a side gate, a control gate, a floating gate and source and drain regions. Appropriate biasing of these gates and source and drain regions controls the electron population of the floating gate. The memory cells may be of either the double polysilicon or triple polysilicon variety. Peripheral transistors are formed from a last formed polysilicon layer to avoid degrading the peripheral transistors.