New phenomena in MNOS retention characteristics that originate from stored charge distribution are discovered and new scaling guidelines are indicated. The most significant phenomenon is that write-state retentivity is less dependent on the programmed depth, and is improved by reducing silicon nitride thickness. This behavior suggests that write-state charges are distributed rectangularly, while erase-state charges are distributed exponentially. The lower limit of the programming voltage is determined by write-state retentivity and not erase-state retentivity, and the write-state charge distribution depth determines that lower limit of silicon nitride thickness. The upper limit of the programming voltage is determined by erase-state retentivity after erase/write cycles. The above scaling guidelines indicate that 16-Mb EEPROM's can be designed using MNOS memory devices.