The answer is yes. The fact that we can be descriptive and positive or negative and descriptive doesn't make us any less designers. Design is a verb, not a noun.
Design is the process of making something, and the process of making something is a verb. It's not a noun. The process of making something is not a design.
Design is the result of making something. The result of making something is not a design.
Design is a state of mind. The state of mind of making something is not a design.
Design is the way we think about making something. The way we think about making something is not a design.
Design is the way we make something. The way we make something is not a design.