That's what I figured, but just wanted to clarify. I'm wondering if it really needs to require ToB, though, since most of the scripting commands for ToB will work in SoA if they are added to the relevant IDS. MakeGlobal(), for example, is the most common way to create NPC mods. If it is added to the Action.ids, there's no need to require ToB.
EDIT:
After downloading the mod and taking a look at the contents, I can't seem to even find anything that would cause this to require ToB. There's no effects over #300 being used, and it doesn't look there's even any scripting commands from ToB. Perhaps I got an old version (doubt it - I just downloaded it from IEGMC Asia)?