The large scale of the proposal, its relevance to the council's vision for the Waikato River and significant public interest were also considered special circumstances, Brockelsby said.
Wairakei Pastoral's main leaseholder, state-owned enterprise Pamu Farms of New Zealand (formerly Landcorp) also pushed for the application to be made public.
Pamu notified the council that if the consent application was not publicly notified it believed that as an affected party it should be consulted, spokesman Simon King said.
"Pamu believes the consent and any others like it should be publicly notified to ensure all interested parties have an opportunity to be heard on the implications for the environment of the proposals," he said.
Pamu leases about 12,500ha of the Wairakei estate, on which it farms 20,500 dairy cows, sheep and beef and has a sheep milking operation.
"We would also note that the (council's) Healthy Rivers plan is still in its very early stages and it makes sense to have more clarity on how the plan will be implemented before proceeding with this application," King said.
"Overall, Pamu has a deep commitment to farming in a way that is environmentally and ethically responsible. This includes working to ensure that we keep the rate of nitrate leaching as low as possible and definitely within agreed limits."
Pamu was not party to the consent application and was not formally consulted by Wairakei Pastoral.
It is unclear whether the land change application would mean additional cows on the big estate, which Pamu, then-Landcorp, began converting to dairying from forestry in 2004.
The Herald made several approaches to Wairakei Pastoral to discuss the application. The office of Trevor Farmer, whose property portfolio is reported to be worth many millions of dollars, said he would have no comment.
Wairakei Pastoral chief executive Chris Parkinson did not respond.
Staffer Nic Conland, who signed the updated application in November, declined to clarify if the land use change would result in additional dairy cows.
Nor would he clarify his covering letter to the council in the updated application, which suggests the application is simply a response to a 2016 council order that Wairakei Pastoral get a new resource consent because of a proposed plan change in which part of its estate was caught.
Pamu's King said his understanding of the land use consent was that it related to land use changes on the estate since 2016 which required consent.
"This is not a new Pamu conversion and does not involve an increase of our dairy activities including cow numbers above what Pamu has previously indicated."
However this has yet to be confirmed by Pamu - and Wairakei Pastoral.
A Waikato Regional Council spokeswoman said the application process was on hold while Wairakei Pastoral considered its options after the council's decision to publicly notify.