Absolutely not! I just went through this over the past few days. There was so much confusion at the beginning of January with the new changes, that they did accept many applications without APs. Now they have had proper training, and will only accept: AP Exchange Voucher numbers or actual AP numbers. They aren't even accepting Will-Call certificates, so if you don't have an AP, then they won't process your application. I would suggest ordering an exchange voucher if you can. If you can believe it, I just ordered mine 5 days ago and then arrived here to Canada today! I did the $3.00 delivery option - it was incredibly quick!
Good luck with ordering your card. I'm sure that other people may post on here saying that they did receive their cards without APs, but I have just been through many phone calls and emails over the past week on this very issue, and the DDE office is very strict about this policy now that there were so many mistakes made in January. I actually ordered my card through Rosa Flores herself today and since I had my Exchange Voucher in hand, it was no problem.
Tiger