Yes, that will work (a 28mm tire). You'll really have to inflate those puppies (depending on your weight) compared with the 38mm tires, so you'll be going in the opposite direction with regard to comfort. But they will definitely work. If comfort is your priority, or at least one of them, then I'd suggest a larger tire, not a smaller one. Continental make a tire called the SpeedRide that is only 420 grams. It's labeled a 42mm tire, but will inflate up to about 38-39mm on a 16mm rim. I own a set of these tires, and I highly recommend them. Their name doesn't lie -- they're fast.