It's technically correct that bcp.exe can only replace the contents of a file and output from SQLCMD can be used to append as well, and if the purpose of the question is to remind people of that, then it's a good question.
However, I would not endorse this as a best practice. If I had to append the results of a query to an existing file, I'd either use bcp to output to a temporary file and then concatenate the two together, or I'd start investigating the possibilities of SSIS.
Remember, bcp.exe is written specifically to quickly import or export large amounts of rows, and is optimized for this purpose, while sqlcmd.exe is a general purpose querying tool that is optimized for ad-hoc queries. Also, bcp.exe gives the user lots more control over the formatting of the results.
Hugo Kornelis, SQL Server MVP
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