It is not.
From the form [1]: "...that has POTENTIAL to create significant risks of identity theft, financial fraud, harmful direct contact, or other specific harms..." (emphasis mine).
The requirements section states that you may request removal due to the page having "personally identifiable info" OR doxxing content "used in implicit or explicit threats".
Now, there's exceptions to this (e.g. public records, newsworthy content), but nowhere it says you have to receive threats first before requesting removal.
disclaimer: Googler, but no relationship with the team, and have no other knowledge of this policy other reading the public blog post.