So here's the update:
NOTE INFO PROVIDED IS FROM UNCONFIRMED SOURCES.
Apparently all 07's and some 08's have a steering column lock, and all 09's and10's do not.
This would mean that if yours does not, you should be able to flat tow with no key at all, and you will not need to disconnect the battery.
The reason for the key is to unlock the steering, the reason for the battery disconnect is to prevent the battery from going dead from the 2-3 amp draw present in the first click key position, so therefore, if you have no lock, you don't need to disconnect the batt.
On a side note the manual's reccomendation that you should disconnect the batt while flat towing is foolish. Firstly, the majority by far of supplemental braking systems for flat towing (which are required by law in most cases and places) require vehicle power to be present to function. Secondly, it is annoying to lose all the presets on the radio and to have to reset the time constantly, not to mention the ecu data that is lost which causes the jeep to run funny and idle high for the first 20 minutes after you reconnect.
At this point I beleive the jk's without steering column locks can be flat towed "as-is", which is a bonus, it's enough hassle to hook up all the other stuff.