In 2012, the U.S. Navy proposed to create a new undersea naval training range immediately adjacent to northern right whale calving grounds in shallow waters off the Florida/Georgia border. Legal challenges by leading environmental groups including the Natural Resources Defense Council were denied in federal court, allowing the Navy to proceed. These rulings were made despite the extremely low numbers (as low as 313 by some estimates) of right whales in existence at this time, and a very poor calving season.