Luis,
From two Unicode experts I have consulted come the following comments:
See:
http://www.unicode.org/reports/tr36/
Cases like this, in which an illegal sequence is explicitly transformed into another illegal sequence, would meet with a lot of resistance from folks who care about security.
It's important not to do anything outside the definition. Your objection to CODE-CHAR returning NIL is incompatible with the Unicode concept of "Noncharacters". See the Unicode report section 16.7.
-- Dan