Abstract: A method for growing tunnel oxides on a specially treated substrate surface. The method comprises steps for roughening the substrate surface to induce low tunneling voltage in the subsequently grown tunnel oxide layer. The tunnel oxide layer is grown in a low temperature steam cycle to further provide enhanced tunneling. The surface treatment comprises the steps of growing a first oxide layer to seal the surface of the substrate followed by growing a second oxide on the first oxide layer. In the preferred embodiment, a plasma etch utilizing an oxide etcher with high energy ion bombardment and an aluminum electrode is utilized to etch through the first and second oxide layers. The aluminum electrode causes sputtered aluminum on the second oxide layer's surface. The sputtered aluminum blocks the anisotropic etching leaving a grass type oxide residue on the substrate surface. The etching continues, overetching into the substrate surface.