Correction Rick,
"I wish to protest that part that the Interurbans did not issue waybills. They most certainly did, as a waybill is as much a bill as the credit card bills that you get in the mail, and was their source of freight revenue."
I did not say something you had to protest. Only said that the Interurbans that did not issue waybills did not come under ICC. Most Interurbans did issue way-bill as carried milk and LCL for example and their lines did come under ICC, and the Sacamento Northern was one example. Albany Southern another. There are some trolley lines which ran over ICC lines in the day time, but did not come under the Railroad Labor Act or ICC control or inspection, but the freight RR that owned the line (operated at night) did come under ICC.
The San Diego Trolley is a case like that today and a new line from Trenton to Camden, NJ, being built.