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No not at all. If a player is purposefully is trying to avoid helmet to head contact, for the most part he is going to be successful thus he will get penalized rarely if at all. OTOH if a player is purposefully trying to cause helmet to head contact, once again for the most part he is going to be successful and will quickly rack up enough offenses to be a repeat offender.
what about a QB who is ready to get sacked who makes sure he gets hit in the helmet to draw a penalty? Goodell is looking at the short term here ... long term there will be ways for this to be abused by all players.
take one in the helmet for the team ... not good and it will begin to happen.