Recent studies by researchers at Penn State have suggested that Northern Right Whales increase the volumes of their calls to counteract increases in environmental noise, such as propeller noise from ships.  This is the first time that an ability to modulate call volume to adjust to environmental noise has been documented  in baleen whales.

Lone whales shout to overcome noise pollution

Just like people in a bar or other noisy location, North American right whales increase the volume of their calls as environmental noise increases; and just like humans, at a certain point, it may become too costly to continue to shout, according to marine and acoustic scientists.