People who think there is a gray area there are being silly. The "bumper cover" is open, period. So a bumper cover with fog lights removed is simply an alternate bumper cover, IMHO. Perfectly legal.
I'm guessing for MANY cars that would run ST there are aftermarket bumper covers out there that would require the removal of the fog lights. It would simply make no sense to allow someone to run one of those and *not* allow someone else to run a factory one with the fog lights removed. I see where the wording could sort of imply that maybe this isn't legit, but a PC with sanity would leave this one alone.
That means you could even drill big gaping holes in your factory bumper cover that just happen to be in a good place for brake venting, air induction, etc.
If you think there should be a wording change to the rule to address this issue, and you are an SCCA member, please write a letter to
seb@scca.com requesting a clarification. That's the only way these gray areas get turned to black and white, and this one shouldn't be that hard to fix. Sometimes we intentionally leave slightly gray areas where writing the rule would be too long to be worth it, but in general the intention is definitely to make things as clear as possible.
--Donnie