FAA's recommendation is to use a carseat or CARES for kids under 40 lbs.
The lap belt's fit to the child can vary on different airlines and seating configurations and with kids of different shapes, even those who have the same overall height/weight.
My daughter is 3 and around the same size (maybe more like 35 lbs.) and she used a Britax Marathon for our last plane trip. But just out of curiosity, I had her sit on an empty seat and buckle up while I was installing her carseat. It actually seemed to fit her just fine. (This was JetBlue, E190 aircraft.)
Would I be comfortable with her in just the lap belt? Maybe -- in the sense that even with potentially sub-optimal protection from the lap belt, she would still be statistically safer than if we drove the same distance with her in a RF carseat.
Of course, she would be safER in a carseat, and we needed one at our destination anyway.
There's not a ton of research in this area, but this FAA report from the 1990s describes lap belt performance on a 50th percentile 3-year-old test dummy as less than ideal but generally acceptable, especially compared to some forward-facing carseats that (at the time) did not do well:
http://www.dtic.mil/dtic/tr/fulltext/u2/a285624.pdf
Overall, although CARES doesn't always get rave reviews, this does sound like the perfect situation for it -- you won't need a carseat at the destination, and the child is old enough (and the flight short enough) that I wouldn't worry too much about unbuckling or some of the comfort issues that are sometimes cited. Alternatively I would consider a lightweight carseat that is easy to get through the airport and can be kept as a spare for travel/carpool/grandparents.