Modelling the holes is really making your life unnecessarily difficult, and there is an argument that SDS is not the way to go with this model because of the hardness of the edges everywhere, and the amount of effort required to get the holes utterly distortion-free despite the curvature of that surface. That is why I come down on the side of VB for this, because it isn't a problem for that.
But, if you are a glutton for punishment it is certainly possible 😉 The principal stages would be thusly...
1. Make a single hole from a 2 x 2 plane, maintaining its square outer perimeter.
2. Clone that into a grid array that closely matches the reference using precise values so the clones meet exactly. Make that editable, and remove the excess clones you don't need on the corners.
3. CO&D all those into a single mesh, and optimize.
4. Expand that section using the existing topology into the rest of the side using normal poly tools. keep the mesh density similar throughout.
5. next, build the sort of low poly SDS mesh I showed above for the whole side panel, but flat - ie with no curve, but with exactly the sort of topology you need to be able to add that curve, which is the edge flow I showed.
6. Get a Mesh Deformer on the holes mesh, make the SDS of the low res model the cage it needs (apply it if necessary), and initialize it while they are both flat.
Now any deformation you add to the low poly mesh will be applied to the high poly holes one too, allowing you to get the curvature you need. However as I mentioned above, this will subtly but noticeably distort the circularity of the holes wherever things get most curvy, and the only way to remedy that is to manually adjust (or fit circle with project to surface enabled) the points on the ones that are wrong once you have applied it.
Lastly you would apply that deformation (CStO) and add thickness via Zero-Extrude and move. the rest of the mesh can be regular mid poly SDS.
CBR