Black Hole Horizon Fluctuations

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 $\sqrt[3]{M}$. The implications of these results for the origin of black hole radiation, the meaning of black hole entropy and the information puzzle are discussed.