If "I can read my source just into the canonical datatype" was the standard for an environment to be meaningfully homoiconic, you could easily argue that bare metal was homoiconic for the same reason. And in fact I'd argue that it would be easier to hand-assemble VAX instructions to write more opcodes in memory (because the VAX-11 had such an extensive and convenient instruction set, especially all of the three-operand bit swizzling and manipulation instructions) than to do C code generation with a base Unix environment.