Not sure if it was the same one but I've read you also want to avoid water (since it doesn't compress). Go for dirt/grass if possible.
[1]: https://en.wikipedia.org/wiki/Compressibility#Earth_science
But also, it makes sense when you think about it a bit, too. Dirt is a mostly heterogeneous mixture of _stuff_ that tends to clump, which leaves great pockets of air in between that can get compressed out. Water, on the other hand, is a homogeneous liquid with _no_ air in between. There's practically nothing to compress!