you are absolutely correct, Brian. Fog lights are to be used when visibility is in fact less than 50 feet. Their beam MUST be aimed down, to improve visibility over only the next 20-30 feet, no more. But for that, they don't HAVE to be positioned lower. The angle of the beam is far more important than where the light is physically positioned. In fact, higher is better since you can beam it down, so that the reflection off the fog will not come directly into your eyes. And white light is a waste in the fog, so I also wonder why Mercedes made the shift!