Comprehensive Performance Assessment (CPA)

I have just become aware of H23, introduced this year for single tier authorities.

My understanding is that H23 is a percentage derived from:
the PI64 return as the numerator;
the total vacant dwellings (in private, RSL and other public sector tenures) given in the HIP Housing Strategy Statistical Appendix as the denominator.

I had overlooked it in the Audit Commission consultation earlier this year, so the NAEPP response did not address it. My first impression is that it is unobjectionable. It restores some recognition of the varying size of authorities' stocks, which was lost when BVPI64 ceased to be a percentage.

What do colleagues think?