Why not? A "GROUP BY" syntax is -- relatively speaking -- more declarative than handwritten imperative code looping through a cursor and dynamically adding to a keys-values data structure to accomplish the same idea.

I wasn't talking about strict definitions of "declarative programming" vs "imperative programming" to satisfy language lawyers.

It was a continuation of the subthread discussion started by carlmr asking why declarative is better: https://news.ycombinator.com/item?id=30098793

So it was just talking about aspects of "declarative" in general...

The idea is at a small scale, one can compare an imperative loop construct to the more "declarative" syntax that accomplishes the same task. Yes, the "more declarative" syntax will be a higher-level abstraction.

Another example of the micro-instead-of-macro type of discussion was C# when it added LINQ (declarative quasi-SQL) and async/await (declarative futures). The language designers and tutorials used the word "declarative" to describe those new language features even though C#-as-a-whole is not formally categorized as a declarative language. Does using LINQ turn C# into a declarative language? No, but nobody claimed that.

But you are right that it is higher level in that it abstracts away the logic behind GROUP BY. In this sense, all declarative programming is higher level.