ABOARD THE MANUTE'A, CA - JANUARY 30: Bottlenose dolphins leap off the Southern California coast on January 30, 2012 near Dana Point, California. A coalition that includes Native American tribes, Earthjustice and the Natural Resources Defense Council is on the National Marine Fisheries Service for more protection for dolphins, whales, and other migrating marine animals from the use of sonar in training by the US Navy on the West Coast. Environmental groups argue that mid-frequency sonar alters the behavior of sound-sensitive marine life and, in some cases, causes fatal results. Some whales are believed to communicate across hundreds of miles of ocean through sound. (Photo by David McNew/Getty Images)