Black Hole Horizon Fluctuations

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It is generally admitted that gravitational interactions become large at an invariant distance of order 1 from the black hole horizon. We show that due to the ``atmosphere'' of high angular particles near the horizon strong gravitational interactions already occur at an invariant distance of the order of √[3]M. The implications of these results for the origin of black hole radiation, the meaning of black hole entropy and the information puzzle are discussed.