The service coverage schedule sets out which services must be in place from communities of a certain size.
Dawson said she was particularly concerned that the DHB believed Lumsden remained covered by the schedule under its maternity plan, as it appeared to have been evaluating Lumsden's distance from primary services - as opposed to secondary services, as set out in the schedule.
"I believe Lumsden to be a geographically strategic centre that provided back up and support for isolated lead maternity carers and equitable care for rural women in a remote area.
"Its closure is dangerous, leaving the remaining workforce isolated.
"Also the data supports that under the SCS the Southern District Health Board requires more primary facilities, not less."
Dawson also questioned the establishment of maternal and child hubs, such as the Lumsden centre has become.
"The hubs at present are just a room of drugs and equipment and the implementation of this has been problematic.
"In the fully implemented plan, 247 support is still not guaranteed via hubs."
SDHB strategy, primary and community executive director Lisa Gestro said Dawson submitted during the plan's consultation period, and her comments were considered.
"Providing maternity services across our vast geographic district is indeed challenging," Gestro said.
"Our responsibility is to use the resources we have to provide the best coverage we can ... the previous system, with no infrastructure in Wanaka, Te Anau, and not enough lead maternity carers working, was I believe, a greater risk for women."
Having the Lumsden Maternity Centre staffed 24/7, with fewer than one birth a week, would never be easy to justify in the context of the health needs of the population, Gestro said.
"We have reinvested these resources into additional payments for midwives in rural locations, paying for business costs such as room rental, and relief midwifery support so they can take time off more easily.
"In its entirety, and with all participants working together, we believe this offers a better primary maternity system of care for the whole district."