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Agreed. I think a lot of it depends on how cynical the offences are and where they are on the pitch.A] That looks like you're wanting to simplify something - which goes against everything that rugby stands for.
B] Do you reset that after giving a yellow? whether for accumulation or one-off?
C] In this case, they'd be right to object, as it's too simplistic. "penalty offence" covers too great a range of sins to then base anything off the US judicial systems (in turn, based on a simplified version of rounders) and say "3 strikes and you're out". There's a world of difference between a cynical laying on the wrong side of the ball within 1m of your own try line, versus an obedience to the laws of physics rather than rugby (someone jumps into you / falls face first onto your arm), or simply being less good than your opponent (scrum).
Typically, it's an accumulation of cynicism, or an accumulation the same damned penalty, or persistent within 5 minutes and 5 metres, and almost always after a final warning has been given. I've no problem with that. Equally, I've no particular problem with codifying it (so 4th cynical penalty = team yellow) - but even then there needs to be an allowance for time frames. Reductio ad absurdium: under the cosh on your own line, and several cynical holdings on to the ball carrier / lying on the wrong side => final warning => spotless play, not a single penalty given away for 50 minutes; then another holding onto the ball carrier 50 minutes after the final warning - that should NOT end up with a team yellow IMO.
If it's foul play, there's no debate. If it's persistent, calculated offences to prevent teams from scoring, even 2/3 penalties in the red zone = yellow is fine for me.
Conversely, let's say there's a series of unrelated penalties for minor/technical offences that occur across 10-15 minutes all over the pitch, I think it's another thing entirely. For example, should an accumulation of a scrum penalty, or a technical lineout offence, a seatbelt tackle, a breakdown penalty etc. be treated in the same way if they're unrelated (I.e. not in the same passage of play) and none of the offences is directly trying to prevent a try scoring opportunity?