Flawless ToO should not be a requirement because a small percentage of the Destiny community actually achieved Flawless by now (maybe 25%). Bungie wants this emblem to be easily attainable by the vast majority of Year One players. Flawless Trials and Flawless Raider etc won't be made requirements. Otherwise, it would defeat the purpose of this emblem. Also, you're forgetting that 9 wins in Trials is considerably harder for the average player than completing VoG, CE or Skolas on Hard.