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As discussed in the applicant's Subdivision Code exception justification statements above, the proposed roadway and drainage exceptions will maximize the number of affordable lots than can be created in relatively flat areas of the subject property while holding down infrastructure costs to further enhance affordability. Finally, the proposed RS-10 zoning in the concurrent change of zone request would allow a mathematical density of 62 lots within the project area, thus the proposed 43-lot subdivision would not result in an intensity of land use higher than that otherwise specified for the district The development of a harmonious, integrated whole justifies exceptions, if required, to the normal requirements of Chapter 23 Hawai'i County Code 1983 (2016 Edition, as amended), and the contemplated arrangements or use make it desirable to apply regulations and requirements differing from those ordinarily applicable under the district regulations. There is a severe shortage of housing in the County of Hawaii. According to the Hawaii Housing Finance Corporation, Hawaii County has a need for 13,542 housing units to account for population growth. Moreover, the need for affordable housing is equally as urgent. The requested exceptions from the Subdivision Code will help significantly defray infrastructure costs related to developing housing on the proposed PUD lots through the applicant's self-help and turnkey affordable housing program. Additionally, given the topographical and physical constraints of the larger parcel upon which the project site is located, all the requested exceptions were carefully considered to enhance lot design and maximize the property's features to be complementary to existing surrounding land uses, including the similarly designed, 40-lot, self-help residential subdivision in the immediate vicinity. Finally, based on consultation with the Planning Department's Administrative Permits Division (the division that previously processed PUD applications), the Director is comfortable recommending approval of the entire slate of exceptions, as there were no significant concerns with what was proposed. It should be noted that the 43-lot subdivision will still be required to go through a formal subdivision process and will be subject to all other requirements of the Zoning and Subdivision codes, less the exceptions requested here. Finally, while the applicant did not request it, the Planning Director also recommends that the Planning Commission grant an exception to HCC §23-95. Right-of-way improvement, which requires a subdivider to improve the entire street right-of-way to standard specifications on file at the Department of Public Works. As the proposed 40-foot-wide roadway will not meet DPW standard specifications, an exception to this section of code will also be necessary to develop the proposed subdivision. The request will not have a signnificant adverse impact to traditional and customary Hawaiian Rights. In view of the Hawaii State Supreme Court's -PASIT' and "Ka Pa'akai 0 Ka'Aina7' decisions, the issue relative to native Hawaiian gathering and fishing rights must be addressed in terms of the cultural, historical, and natural resources and the associated traditional and customary practices of the site. Investigation of valued resources: An Archaeological Inventory Survey (AIS) entitled, "Archaeological Inventory Survey of 7W. (3) 6-2-001: 075 portion, Ouli A 11huplia'a, South Kohala District, Island oJ'Hcnvai'i "was produced by Ogden Environmental and Energy Services, Co., Inc. In 1990, revised in 1993 and approved by SHPD in 1994. The AIS was originally created for the evaluation of the Waikoloa Maneuver Area, a 91,000-acre area used for military training exercises during World War 11, which includes the proposed project area. N