Note on covariant action integrals in three dimensions

We compute -in the saddle point approximation- the partition function for the 2+1 black hole using the Gibbons-Hawking approach. Some issues concerning the definition of thermodynamical ensembles are clarified. It is pointed out that the right action in covariant form is exactly equal to the Chern-Simons action with no added boundary terms. This action is finite, yields the right canonical free energy and has an extremum when the temperature and angular velocity are fixed. The correspondence with a 1+1 $CFT$ is indicated.