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It doesn't "require" any drilling but in order to make it sit tight against the bumper you're going to need to drill or 3m it.
I'm personally going to drill because I don't trust that fastening just the bottom will hold and to make sure I get very tight fitment. Also, I want to be able to remove this in the winter in the event we get deep snow.. 3m would be a pita to deal with. Not concerned with holes because they're on the underside and you wouldn't see them unless the bumper is off the car or you're laying on the ground.
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