According to the ANO there is no such thing as a BCPL therefore; you do not have a valid licence! A bit of a shock I know, but as CAP 804 is not a legal document, I fail to see how the statement in it can validate a licence that no longer exists in law.
I believe that you should or rather must apply for a valid licence and you have two choices, either use SRG1102 to apply for a UK CPL which will contain the privileges published in the ANO Schedule 7 these include the privileges of a PPL with an IMC rating. Additionally it does not contain the limitations that the IMC rating is designed to remove. The statement in CAP 804 clearly gives you a right to move directly to this licence.
You can also apply for an EASA licence subject to meeting the conversion criteria, using SRG1104 which includes the option to retain a UK National (lifetime) licence which I think represents a more economical solution.
If you use the 1102, you know you are going to have to pay again to go down the EASA route in 2 years time!
Remember, the CAA letter of 2010 stated that its the pilot's responsibility to ensure that you are in compliance with the law, at the same time they absolved themselves of any further responsibility to notify you of any changes that might affect your legal rights!
Last edited by Whopity; 17th Jan 2013 at 10:39.