Yes. I don't know about the other years, but the 2nd gen non-LSE doesn't have an internal bulb shield in the foglight; that's what the black cap on the bulb is for. Without the shield, oncoming traffic will be staring right at the arc of the HID bulb.
Even if yours has a bulb shield, the HIDs are significantly brighter than the halogen bulbs. The 9145 bulbs (2nd gen non-LSE) are rated at 1000 lumens, stock 35W HIDs are 3200 lumens, and driving them with a 55W ballast probably gets you over 4000 lumens (just guessing on this one).
Too much near-field light is detrimental to both you and other drivers. Foglights are designed to produce a low, wide beam on the ground to allow you to see what's directly in front of you when driving very slowly in conditions of severely reduced visibility. When driving with them at highway speeds your eyes adjust to the increased light directly in-front of the car, reducing your ability to see what's in the distance. Also, the increased light directed towards the ground reflects off of the road towards oncoming traffic (especially on wet roads).
For anyone looking to match the color of their foglights to HID headlights, I'd recommend LEDs. They won't be very bright, but most people don't encounter situations where foglights would be necessary so that's not really a drawback. You get the look without hindering your visibility or that of other drivers.
