From the qoute of the ANO, does it not say 100hrs over 28 CONSECUTIVE DAYS rather than a period of 28 days.
(a) during the period of 28 consecutive days expiring at the end of the day on which the flight begins exceeds 100 hours; or
That would then mean that for each day off a further 100hr block would become effective. i.e. 125 flying hours within a CALENDER MONTH is OK, in regard to the ANO.
The FIE qouted perhaps has a point