With Hájek, we defined and explored L-valued universes for various algebras L pertaining to fuzzy logics, among them, for {\L}ukasiewicz logic. We then introduced an axiomatic set theory and showed that formulas provable in the theory are valid in the universe constructed over L. In this talk, I would like to explore the limitations of this method for MV-algebras. In particular, I'm interested in two problems. 1) the role of the $\Delta$ connective in our construction; we did not attempt to work without it, and 2) the role of the choice of a particular MV-algebra. This is part of a larger investigation that seeks to find out various ways of model construction for set theories over substructural logics, and eventually determine limits of consistency for them.