Hi Daniel,
I'm very sorry for confusing information, forget my first response please.
You need to use local address as you do at first.
Your error will happen, when you use PAGE_0AStart: equ $00028000 -> this address is global and you are accessing out of memory.
When you want to access on the PAGE 0xA, you need to use alternative addressing for PPAGE.
So, address will be $0A8000

This should work:
ORG $4000
entry: LDS #$4000
LDAA #$01
CALL sub1
INCA
loop: BRA loop
;-------------------
ORG $0A8000
sub1: INCA
RTC
I hope it helps you.
Best regards,
Diana