 The second approach, outlined above, refusing grounding but favouring truth-making, is advanced by Heil (2016). Heil is generally suspicious of grounding because, he points out, grounding is often characterized in different and incompatible ways, so he is sceptical that there is a univocal concept of grounding to be had. But, more specifically, Heil has long maintained that hierarchical conceptions of reality spell trouble because of the difficulties explaining the causal and nomological relationship between the layers (Heil 2003: 31–9). He argues that this was the problem identified for supervenience and realization in the ‘90s and it’s a problem inherited by the hierarchical conception of reality to which grounding gives rise. So Heil does a modus tollens where Fine does a modus ponens. Whilst Fine conceives of the hierarchical styles of explanation grounding provides as one of the principal virtues of grounding, Heil considers this is one of the deepest drawbacks of grounding. By contrast with Fine, Heil instead recommends truth-making as the proper methodology for metaphysics because it enables us to give a non-hierarchical description of reality whereby fundamental physics gives us the truth-makers for truths that have truth-makers. Further and independent objections to grounding include whether the notion of grounding is intelligible (Daly 2012), theoretically unified (MacBride 2013b), theoretically illuminating (Wilson 2014) or the result of a cognitive illusion (Miller and Norton 2017).