It's not just an allocated vs used space issue. With EBS you are also paying for I/O ops while the volume is mounted.
I am trying to do the same thing -- migrate an EBS-backed instance to an S3-backed instance. Other threads here on SO state that this can't be done [1], but a response to an AWS forum post by Eric Hammond suggests that there is hope:
Using the concepts of swapping out a boot disk in a running EC2 instance as described in the following thread
http:// developer.amazonwebservices.com/connect/thread.jspa?threadID=42437
you might be able to create an EBS volume in the new region with a copy of the raw bits from the old region's volume, then swap the new volume into a stopped Windows instance in the new region.
Once that's working, normal AMI creation from the running instance should be possible
Not for the timid, but if it's important you might be able to find an EC2 Windows expert who can help with the steps.
Not exactly definitive, but Eric knows what he's talking about, so if it's important enough to you you can give it a try.
1 - stackoverflow.com/questions/2453852/ec2-booting-from-an-ebs-snapshot-and-then-detaching-the-volume-to-reduce-costs