Yes. You average ~41 moves and you get a 32. Possible. I got a 30 and I average 38-39. What does he average? World class FMC solvers get 1 sub-20 every hundreds of solves. You're telling me he is world class at FMC?
How do you know he averages 28 moves? And do you know how hard it is to improve when you're at lower levels? Okay, by your argument if someone averages 21-22 moves they should be able to get sub-20 move solves at least once every comp. Is that happening? No.
Hm... Can you give us some example solutions? Here are three randomly generated scrambles:
R' U' F U2 D' L2 D2 F L B' R U' F2 U2 L2 D2 F D2 L2 B' L2 U2 F' U2 R' U' F
R' U' F U2 L' D2 F2 R D2 L' U2 R' D' F' D R2 B' L2 F2 R' D R' U' F
R' U' F D R2 L2 B L U D2 F2 R D2 B2 R' B2 U2 L F2 R D L R' U' F
Just take it as a practicing session. Unless you have a comp with FMC coming up I'm staying skeptical.