I bet this is just lazyness. The installer didn't have a GFCI breaker on the truck. By the time he buys a GFCI receptacle, box and wire plus the labor to install it, he cost his boss money. If this was really intending to provide a needed receptacle in that location he should have taken the downstream load out of that box.
Breaker - about 3.00 GFCI receptacle - about 9.00
GFCI breaker - 32.00 minimum.
Could have been a simple economic decision. Many contractors install a seperate GFCI device instead of using a combination GFCI-Circuit breaker because it's cheaper, and easier to diagnose problems over the phone. Breaker trips - Overload or short but definately not a ground fault. GFCI trips - defective GFCI or an actual ground fault, but definately not an overload or short circuit.
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