Originally Posted by SilverSport
If the toe is off would it have an effect on this?
It *might* but if would have to be off a decent amount to really make serious noise (unless it's toe out).
However, a 245/17 tire at 31psi isn't "low." That's perfectly normal tire pressure. My tires (33x12.50x15 Duratracs) do make a very slight noise when full lock slow turning (ie a uturn) but nothing I would call "loud."
The OP should check his sidewalls and see if there is a "roll" mark (a shiny-er ring) around the tire which would indicate rolling.
It shouldn't be making any noise at speed (Id say 15mph+) so if the noise is still there (don't confuse with tire roar) then the issue lies elsewhere.
Bad toe would be noticeable at all speeds, seriously premature tire wear, weird steering feel, etc.
The OP did say that the ride got come compliant, so the tires obviously softened up. Remember, it's a Jeep, some things are noisier on a Jeep than a normal vehicle.