We suck at penalties and are ranked in the 80s.
I do think the lack of turnovers and turnover differential are a big part of why we are 2-1 without having many other stellar statistics.
And the penalties, while plentiful, don't seem to have hurt us much — they mostly haven't occurred in key situations. OTOH, we've benefited from a few key penalties going the other way, such as the PI in the end zone on 3rd down vs Wisconsin. Had we scored a FG instead of a TD on that drive, the final result might have been very different.