“…These clearly influenced the design of the EU Emissions Trading Scheme (ETS), for example. However, determining the achievement of de jure GHG mitigation targets is a phenomenally complex socio-technical enterprise involving myriad MRV rules and layers of public and private governance practices through which 'facts on the ground' are translated into quantifiable, fungible and tradeable emissions units (Kuch, 2015;MacKenzie, 2009;van Zeben, 2014). Numerous studies have demonstrated how a combination of 'generous' accounting provisions relating to land-use and forestry, tradeable 'hot air' credits, and tradeable project-based credits of dubious environmental integrity ultimately gave states wide interpretive latitude in achieving their Kyoto targets (Kollmuss et al, 2015;Kuch, 2015;Schneider and Kollmuss, 2015;Shishlov et al, 2016;Stavins et al, 2014Stavins et al, , pp.…”