Thanks for the reply Neil! As for my work flow... I work with people that change their minds! :)
Lets say I have a square foundation I have to label each corner with an elev. So I do that with labeler. Yep, once I jump through the hoops of getting all my settings correct, placing 4 is as easy as 1. But then "we" decide a circular foundation would be much more estheticly pleasing so I delete my square foundation (along with the broken spot elev labels) and draw a circle foundation. Oh, esthetics are nice but they cost too much - change that back to a square foundation. Ok, delete the circle (along witht he broken spot elev labels) and draw the square again and label again. Wait - let's make the foundation an "L" shape... repeat the process... If the labels were not tied to an element, then I would only have to move them to the correct x,y location and they would update according to which surface I choose in label updater. Even when there are more required (each corner of an "L" instead of just four corners or quadrants of a circle) I can simply use basic MicroStation commands of move and copy instead of loading geopak, labeler, change/verify settings...
I guess I expect a level of editablity that's beyond what is available with geopak? That'd be great if labels move with, but if the target elem is deleted altogether I'd rather the spot remain intelligent as to the surface instead of being totally unusable.