They even explicitly stated that!

If there are mods here who are willing to work towards reopening this community, we are willing to work with you to process a Top Mod Removal request or reorder the mod team to achieve this goal if mods higher up the list are hindering reopening. We would handle this request and any retaliation attempts here in this modmail chain immediately.

This system is being implemented for the sole purpose of kicking out mods that are keeping subs private. It's absolutely retaliatory. There's no chance that they maintain this system as an actual long-term change to reddit's mod removal policies. It would be too much overhead to staff.