I did it.
yes you have to remove the bumper.
Also to remove the bumper there is a screw attaching the bumper to the arch, hidden inside each wheel arch... so you should also remove the inner wheel arches - can be done with wheels attached!.. you could maybe do it only removing part of the crews for the inner arch.. but it's so much easier to just remove it completely.
Them disconnect the fog lights and remove the other ~8 visible screws ( torx t35 maybe)
pull the bumper off.