 The first approach, taken by Fine, involves embracing grounding but rejecting truth-making. It’s truth-making, he argues, we can do without; grounding does a better job (Fine 2012; 43–6). Here truth-making is conceived as a relation between a worldly entity and a representation: the existence of the entity guarantees the truth of the representation. But, Fine argues, it is more theoretically fruitful to take grounding as the central notion for metaphysics. This is partly because, Fine maintains, grounding is a less restrictive notion than truth-making, because grounding does not require that the ultimate source of what is true should lie in what exists, rather we can remain open about what form grounding takes. Moreover, whilst there may be genuine questions about what the ground is for the truth of the representation that p there may be further questions about what makes it the case that p and these questions will typically have nothing to do with representation as such. Because truth-making is typically understood in modal terms, i.e. necessitation is conceived to be sufficient for truth-making, Fine is also sceptical that there is any way of avoiding the over-generation of truth-makers we have already discussed (see 1.1 and 1.2 above). Finally, Fine thinks that we should be able to conceive of the world hierarchically, whereby (e.g.) the normative is grounded in the natural, the natural in the physical and the physical in the micro-physical. But this is difficult to do if we think in terms of truth-making, because if (e.g.) we conceive of a normative representation being made true by the existence of something natural, that natural thing is just the wrong sort of thing to be made true by something at the physical level because it is not a representation. 