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EDIT: You can't convert the atmosphere of a None atmosphere planet. You have to blow it up and rebuild it so that it has an atmosphere to work with.
If this is true it is definatly something new. I used to convert non-aptmosphere moons all the time. It's been a while since I have done it in a game so I guess it's possible it has been patched out, although I can't imagine why.
One thing you can't do is convert a Gas giant planet to a none aptmosphere. That is the only restriction I know of.
Geo