CCG Size: designed to fail

I have taken the data from the Department of Health for the current Clinical Commissioning Groups. The relevant figures are:

CCGs
Number of CCGs: 266
Mean population per CCG: 198,973
Median population per CCG: 167,210

PCTs

Number of PCTs: 152
Mean population per PCT: 340,900
Median population per PCT: 282,200

I have plotted out the numbers of PCTs and CCGs in various population bands:

The PCTs are in dark blue and the CCGs are in light blue. It is immediately obvious that the centre of gravity of the graph of the CCGs is much lower than for PCTs: the clinical commissioning groups are much smaller than PCTs. More concerning is that out of 266 CCGs four fifths of them (219) have populations less than 300k. (For comparison 87, or 57% of PCTs were under 300k.) Three hundred thousand is the figure given by Civitas as the rough rule of thumb for the minimum size for a commissioning group to be financially viable:

In 10 European countries analysed, seven have seen a consolidation of commissioning organisations over the past 15 to 20 years, two have seen no change. In only one country (Spain, due to devolution) has the number of commissioning organisations increased. In all countries apart from Switzerland the average population coverage of a commissioner is above 300,000 people.

With so many small CCGs is GP commissioning designed to fail?