17 of 30 of the Ladies in Nice, 11 of the 24 who skated the FS, did not score 28 in the SP:
Marchei, McCorkell, Lacoste, Silete, Czisny, Lafuente, Korobeynikova, Popova, Hecken, Frank, Mikonsaari, and the six Ladies who didn't make the FS.
Silete and Korobeynikova earned the minimum at Euros (and may have at other competitions). Czisny at GPF, Popova and Silete at NRW, Frank and Marchei at International Challenge Cup.
Hecken narrowly missed at Nebelhorn. Lafuente narrowly missed at TEB. Lacoste's highest score was 26+. Unless I've missed a score, McCorkell and Mikonsaari weren't even close. All would have qualified for Euros/4C's, with a minimum of 20.
I didn't check the six who didn't make the free skate. Since the FS scores in the
Prelims for those who didn't qualify for the SP ranged from 23-~37, I doubt that any of them scored 28 in the SP in international competition. (I didn't see any notable SP skaters in this group.)
Lafuente's base content at Golden Spin -- 3F, 3Lo/2T, 2A, 2-L3 spins, 1-L4 spin, and L3 FW, not exactly shabby -- was 27; the TES minimum for Worlds is 28.