I like the way you're thinking! :)
Seems like it would work. I suppose there's only one way to find out.... :)
When you import back in, the entries will get added *to* the blog. It won't write over existing entries. (So there will be two of everything... one set with comments and one without.)So you'll most likely want to import into a blog that has no entries.
But what about the ALLOW COMMENTS part? You will need to edit that line also.
If you aren't going to use comments at all, you could remove the comment tags from the templates, then they just won't show. That's cheating a bit though.