That is not my understanding. You need cellular to have GPS. I have a friend who recently purchased a Wi-Fi only iPad and it did not have GPS. If you Google around, this is the only answer you will see. If Wi-Fi only, it will rely on your Wi-Fi connection to determine where you are. If you are imaging from your home, that should not be an issue. If you are out in the middle of nowhere, you are out of luck.
JohnD