I wouldn't have thought so. I didn't have to remove mine to fit the cooler, but they sit directly in front of them on both sides as you can see from my other pics. Removed them to increase flow across the coolers as I don't think I've ever really used my fogs.Does this mean a 1.9tdi will loose fogs with a 2.5/other side mount intercooler?
I did consider on my headlight build using some mk4 golf foglight projectors in them as a compromise as they are tiny.
When I had my turbo replaced after it destroyed itself I had a new intercooler so there would be no hidden debris in the system, so hopefully that side is leak free.