In the latter case, the stipulation of 220.51 would prevent the feeder from having a lesser size than the heater's branch circuit.If the feeder supplies only a single branch circuit and that circuit has only heating loads, then the effect is to apply the 125% to the feeder also. But if there is more than one branch circuit, it is very easy to have the feeder smaller than the calculation of the heater loads as continuous for the feeder ampacity calculation would require.
Say for example we had a feeder with one 3kW noncontinuous heater and two 120V receptacles, non-dwelling... perhaps a guard shack. The heater branch circuit minimum size is 3.75kW while the feeder minimum by calculation would be 3kW + .36kVA = 3.36kVA. The feeder minimum must be upsized to 3.75kVA.