This was created as a fileset for /tools to ease in the writing and installation, but there are advantages to it being a single-page RESTful service. Were it a single page, it could be managed easily in the sitemap, as well as having (advanced) user permissions so certain users could be given the ability to run imports. This may be a more unusual case, since generally only the admin will be the one bulk-loading migrated users.
If the controller had a mini-router in on_start() to render GETs on the view (ie a GET will be equivalent to userexport.xml or userexport.json), a POST could update your existing users database by inserting new users that don't exist yet, and a PUT could either replace the users that exist in the 'to' site with the users from the 'from' (or potentially even disable all the old users, so you're swapping out your current user DB with the migrated one.)
URLs could be a bit nicer than when this is a tool too, e.g.
http://mysite.com/lum/users/json
a GET, would get all your users as json, and POST your users as:
http://mynewsite.com/lum/users/?xml=http://mysite.com/lum/users/xml
A really big plus would be that if this were a single page, I could put in configurable parameters to apply transforms to the imported/exported data. This would be a pretty easy way to say "always turn attribute 'name' to 'full_name'" or move them from group 'staff' to 'employee'. Aside from editing the code, there's not really a nice way to do this for /tools
Overall, it's a bit of work to do, and might actually be less usable to people than the tools, so I won't be committing much work to this right now.
could grab all your users as JSON