These days, the term "fine art photography" really has nothing to do with the quality of the photo, but the intended use of the photo. Fine art as opposed to commercial art, IOW. Using the term also comes into play when you're doing search engine optimization for websites, too...people actually use the term "fine art" when looking for art to hang on their walls.

bobbi c.
fine art and not so fine art photography
http://www.bobbichukran.com