I guess the ease of using a stirplate vs swirling is a bonus for stirplates, along with increased cell counts, and a more reliable prediction on cell counts if using a stir plate.
Non stirred starters rarely have a growth factor of more than 2.5ish and very rarely above 3.
Stirred starters have growth rates much higher, and have a growth rate of up to 2B cells per gram of extract while non stirred shaken have a rate of 0.6B cells.
While this may be adequate, bear in mind there is almost no reason to do a small (sub 3L) non stirred starter. You might as well just pitch a second packet.
Considering DME is around $1 for 100g you're spending $1 to grow an additional 60B yeast, while simply stirring it will get you closer to 140B or 2.5 times as effective.
A simple illustration is a packet of yeast with a manufacture date of 6 weeks.
Viability 72%
Starter size 2.5L
Inoculation 28.8 million / ml
Stirred: 353B new cells total 425B
Shaken: 156B new cells total 228B
A good pitch rate for a Lager is 1.5m/ml per plato. For a 1.045 lager you need 336B cells so by simply stirring a 2.5L starter you can actually harvest 500ml and still pitch the required number.
Simply shaking you are pitching 100B less than ideal.
Yes, lots of people make good beer without starters and simply pitch 1 packet of liquid yeast. But in my opinion, having a stirrer is a cheap insurance policy. I make wort, yeast makes beer.
Its easy in my own opinion to simply pop the flask on a stirrer and forget about it for 2 days.