The applicant's response was that exhibit C was not a map prepared in accordance with the Department's rural land evaluation manual (exhibit G), but even if it were, it does not amount to evidence of what the expression ".... prime agriculture land ...." means in its plain and ordinary meaning. In other words, it was contended that exhibit C does not classify the subject land as class 2 within the Department's manual, and, accordingly, the subject land has not been so classified. Even if it had been classified, it would be class 2 land, but that classification does not provide the meaning of "prime agricultural land" which still requires interpretation. What was needed, therefore, was to have regard to the factors which, in the opinion of experts, would apply in order to determine that the subject land is not prime agricultural land, either as contemplated by that manual or generally.

In support of its contention that the subject land was not prime agricultural land the applicant called several expert witnesses - Mr Luke, Mr Leedham, Mr Hudson and Mr Hooper. They each testified as to the factors which they would take into account in order to determine if land was prime agricultural land, being matters such as economic viability, availability of water or soil conditions. They each considered that the subject land was not prime agricultural land because it failed, for one reason or another, to meet the relevant factors.