I think a some people might consider Gursky an "artist who uses photography" more than a photographer, and certainly they would say that about a lot of the conceptualists who have been popular since the 80s.
But I don't think it's as much about process being second to intent as much as it's about the traditions they come out of (and don't come out of).
There are a lot of people who are considered photographers who don't care much about process--guys like Walker Evans, or just about any photojournalist. But they keep the photographer label because they come cleanly out of photographic traditions, not traditions more commonly tied to other media.
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