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Victims' families fight to keep their ceremony at ground zero.

Families of Sept. 11 attack victims, angered by city plans to move an annual commemoration ceremony away from ground zero, filed a permit request Wednesday asking to hold the event at the World Trade Center site.

The coalition filed the request with the Port Authority of New York and New Jersey, which owns the site. The agency says construction at the site would make a ceremony there unsafe, but family members plan to sue if they are denied.

"This is the place we have. A precedent has been set in letting us touch ground zero," said Diane Horning, a representative of one of the family groups.

Rosaleen Tallon of Advocates for a 9/11 Fallen Heroes Memorial noted that remains of people killed in the 2001 terror attack are still being found at the site.

"How can we possibly not go there to memorialize these people?" she said. "It is still their resting place, and I want to be there."

Work pauses for day

The city has said that ground zero, now undergoing reconstruction, is not safe for the large annual gathering, and it plans to move the recitation of names to a nearby plaza.

Relatives of the victims of the 2001 terrorist attacks will have some access to the site - just not to the pit and not for a ceremony, Mayor Michael Bloomberg said.

"It's just not safe," Bloomberg said. "Listen, we've had enough tragedy on that site. Our first priority, No. 1, is to make sure that everybody's safe, and nothing's going to get us off that."

Attorney Norman Siegel, who is representing the families, said that if the Port Authority rejects the permit, the families would consider a federal lawsuit on First Amendment grounds. He said that the groups had gotten consultations on safety and security and that the site would be safe as long as the construction was halted the day of the ceremony.

Port Authority spokesman Stephen Sigmund said construction would be stopped that day but the site still was not suitable for the ceremony.

"We are actively looking at ways to accommodate family members who want to pay their respects on the World Trade Center site on 9/11," he said, "but the substantial construction activity and current site conditions will not allow the formal ceremony to be safely conducted on the site."

Site to open in 2009

Every year, the names of the dead have been read aloud from a platform along the western edge of the lower Manhattan site. The roll call stops only for moments of silence at the times the two planes hit and the twin towers collapsed.

During the reading, and throughout the rest of the day, families have had access to the seven-story pit that was once the towers' basement, where they would lay flowers.

Bloomberg said family members will be able to leave flowers in an area along the southern edge of the site, but they won't be allowed into the pit.

"There isn't a place to do that anymore, unfortunately, and next year there will be even less," he said. "The next time you'll be able to have a ceremony on the site is really when we complete the memorial."

Construction on the memorial began last year, and it is expected to open in 2009.

A spokeswoman for New Jersey Gov. Jon Corzine said his office was reviewing a letter from the families advocating for the ceremony to be at the original site.

"There must be significant logistical concerns with having a memorial in an active construction site, but those must be balanced with the reality that this is, and will always be, sacred ground," spokeswoman Lilo Stainton said.