Fitzgerald, speaking on ESPN in the video above, said replacement officials have applied inconsistent standards for penalty enforcement.
With that in mind, I've put together a chart comparing penalty counts for defensive backs through Week 3 against three-week averages for the previous four seasons. Eight calls for illegal contact in Week 3 brought season-to-date averages closer in line with recent norms. Replacement officials have called far more penalties for defensive pass interference and defensive holding. Penalty info comes from Hank Garguilo of ESPN Stats & Information. It includes declined penalties.
Receivers have been called for nine offensive pass-interference penalties. That is the same number as there were through three weeks last season. WR penalties for false starts are up, but those for illegal shifts are down to zero from four last season and six the year before.
Regular officials are reportedly close to reaching new contracts. It's unclear how quickly they would resume working once a new deal is struck.