Point (2) above states that the HoT should have extensive experience instructing for professional licences i.e. should have instructed to CPL level and more so it's not as simple as just getting a CPL.
Actually, it doesn't specifically say that HoT needs to have a CPL but I can't think of any circumstance where one could have said "extensive experience" and not hold a CPL.
But, I still think it's irrelevant for a school which only wants to instruct up to PPL level.
Cheers
Whirls