BYBEE, Circuit Judge:
Marcelo Martinez-Cedillo was convicted of felony child endangerment under California Penal Code § 273a(a) and ordered removed on the grounds that his conviction qualified as "a crime of child abuse, child neglect, or child abandonment" under INA § 237(a)(2)(E)(i), 8 U.S.C. § 1227(a)(2)(E)(i). His petition for review requires us to decide whether to defer to the Board of Immigration Appeals' ("BIA's") interpretation of a crime of child abuse, neglect, or abandonment under Chevron, U.S.A., Inc. v. Natural Resources Defense Council , 467 U.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984). Our sister circuits have split on this precise issue. See Florez v. Holder , 779 F.3d 207 (2d Cir. 2015) (deferring to the BIA); Ibarra v. Holder , 736 F.3d 903 (10th Cir. 2013)
*982(not deferring); see also Mondragon-Gonzalez v. Att'y Gen. of the United States , 884 F.3d 155 (3d Cir. 2018) (deferring); Martinez v. U.S. Att'y Gen. , 413 F. App'x 163 (11th Cir. 2011) (deferring).
We join the Second Circuit in deferring to the BIA's reasonable interpretation. We further hold that California Penal Code § 273a(a) is categorically a crime of child abuse, neglect, or abandonment, as interpreted by the BIA. Finally, we hold that the BIA's interpretation applies retroactively to Martinez-Cedillo's conviction. Accordingly, we deny the petition for review.
I. FACTUAL BACKGROUND
Marcelo Martinez-Cedillo is a citizen of Mexico and, since 2005, has been a lawful permanent resident of the United States. In August 2008, he was convicted of driving under the influence of alcohol ("DUI") with two prior DUI convictions. At the time of his final DUI, he had a child in his car who was not wearing a seatbelt. For this reason, he was also convicted of felony child endangerment under California Penal Code § 273a(a).
The Department of Homeland Security initiated removal proceedings on the grounds that Martinez-Cedillo's conviction under California Penal Code § 273a(a) was a crime of child abuse, neglect, or abandonment under § 1227(a)(2)(E)(i). An Immigration Judge ("IJ") entered a final order of removal, which Martinez-Cedillo appealed to the BIA, arguing that (1) California Penal Code § 273a(a) is not a crime of child abuse, neglect, or abandonment, and (2) he should be allowed to apply for cancellation of removal under 8 U.S.C. § 1229b.
The BIA affirmed in part and remanded in part. The BIA held that California Penal Code § 273a(a) was categorically a crime of child abuse, neglect, or abandonment under its prior interpretation of that phrase in two precedential opinions: Matter of Velazquez-Herrera , 24 I. & N. Dec. 503 (BIA 2008), and Matter of Soram , 25 I. & N. Dec. 378 (BIA 2010). Nevertheless, the BIA remanded for the IJ to consider Martinez-Cedillo's eligibility for cancellation of removal.
On remand, Martinez-Cedillo initially requested cancellation of removal but later conceded that recent authority defeated his request. He then, for the first time, moved for a continuance of removal proceedings based on a pending visa petition his father had submitted on his behalf. The IJ denied his motion for a continuance and again entered a final order of removal. Martinez-Cedillo appealed to the BIA a second time, and this time, the BIA affirmed in full.
Martinez-Cedillo now petitions our court for review, arguing that (1) the BIA's interpretation of a crime of child abuse, neglect, or abandonment to encompass criminally negligent acts that do not result in actual injury to a child is unreasonable; (2) California Penal Code § 273a(a) is not categorically a crime of child abuse, neglect, or abandonment even under the BIA's interpretation; (3) the BIA's interpretation should not apply retroactively to his 2008 conviction; and (4) denial of his motion for a continuance was an abuse of discretion.
We first review the history of the BIA's interpretation of § 1227(a)(2)(E)(i), and then address each of Martinez-Cedillo's arguments in turn.
II. THE BIA'S INTERPRETATION
A. Rodriguez-Rodriguez
In 1996, Congress enacted the Illegal Immigration Reform and Immigrant Responsibility Act ("IIRIRA"), which added § 1227(a)(2)(E)(i) to the INA and made "a crime of child abuse, child neglect, or child abandonment" a deportable offense. Two years later, the BIA made a passing reference *983to § 1227(a)(2)(E)(i) in Rodriguez-Rodriguez , 22 I. & N. Dec. 991 (BIA 1999). At issue in that case was 8 U.S.C. § 1101(a)(43)(a), which makes "sexual abuse of a minor" an "aggravated felony" for purposes of 8 U.S.C. § 1227(a)(2)(A)(iii). The BIA held that Texas's offense of indecency with a child was "sexual abuse of a minor" and thus an aggravated felony under § 1227(a)(2)(A)(iii), even though the Texas statute did not require physical contact with a child. The BIA reasoned that the term "sexual abuse of a minor," like the term "child abuse" in § 1227(a)(2)(E)(i), could refer to conduct that did not involve physical contact:
We note that in including child abuse as a ground of removal in section 237(a)(2)(E)(i) of the Act, Congress likewise did not refer to a particular statutory definition, although in the same section it did designate a statutory definition for the term "crime of domestic violence." By its common usage, "child abuse" encompasses actions or inactions that also do not require physical contact. See [Child Abuse , BLACK'S LAW DICTIONARY (6th ed. 1990) ] (defining child abuse as "(a)ny form of cruelty to a child's physical, moral or mental well-being").
Id. at 996. Rodriguez 's passing reference to child abuse was dictum and did not purport to offer a precedential interpretation of what constitutes a crime of child abuse, neglect, or abandonment under § 1227(a)(2)(E)(i).
For several years following Rodriguez , the BIA never interpreted the phrase "a crime of child abuse, child neglect, or child abandonment" in a precedential opinion, and its unpublished decisions on the subject were equivocal. Some unpublished decisions during this period stated that "child abuse" means "the physical or mental injury, sexual abuse or exploitation, or negligent treatment of a child." In re Palfi , 2004 WL 1167145 (BIA 2004) ; In re Baez-Cazarez , 2004 WL 2952229 (BIA 2004). Other unpublished decisions hewed to the Black's Law Dictionary definition of "child abuse" as "any form of cruelty to a child's physical, moral or mental well-being." In re Pacheco Fregozo , 2005 WL 698590 (BIA 2005) ; In re Maltez-Salazar , 2005 WL 952489 (BIA 2005) ; In re Manzano-Hernandez , 2005 WL 698392 (BIA 2005). In short, the BIA's interpretation of a crime of child abuse, neglect, or abandonment was unclear at this time.
B. Velazquez-Herrera
In 2006, we considered the BIA's holding that a conviction for assaulting a child under Washington's fourth-degree assault statute was a crime of child abuse. Velazquez-Herrera v. Gonzales , 466 F.3d 781 (9th Cir. 2006). We recognized that the BIA had previously used at least two definitions of "child abuse," which were "not entirely consistent" with each other. Id. at 783. We held that the "cruelty" definition cited in Rodriguez 's dictum was not "a statutory interpretation that carries the 'force of law' " and accordingly remanded "to allow the BIA in the first instance to settle upon a definition of child abuse in a precedential opinion." Id. at 782-83.1
The BIA followed our instructions and, in May 2008, issued its first precedential *984interpretation of what constitutes a crime of child abuse. Velazquez , 24 I. & N. Dec. 503. The BIA reasoned that, although § 1227(a)(2)(E)(i) defined "a crime of domestic violence," "other operative terms, including 'crime of child abuse,' were left undefined, triggering the negative inference that Congress deliberately left them open to interpretation." Id. at 508. The BIA further observed that, "[i]n view of the fact that [ § 1227(a)(2)(E)(i) ] is the product of a significant expansion of the grounds of deportability and was aimed at facilitating the removal of child abusers in particular," Congress intended a crime of child abuse to be interpreted "broadly in this context." Id. at 509.
The BIA considered various federal statutes defining "child abuse" and related concepts as of the date Congress enacted IIRIRA and found that "the weight of Federal authority ... reflected an understanding that 'child abuse' encompassed the physical and mental injury, sexual abuse or exploitation, maltreatment, and negligent or neglectful treatment of a child." Id. at 511. The BIA also considered state criminal and civil statutes, concluding that "there was a growing acceptance by 1996 that the concept of 'child abuse' included not just intentional infliction of physical injury, but also acts of sexual abuse or exploitation, criminally negligent acts, or acts causing mental or emotional harm." Id. Finally, the BIA noted that the most recent edition of Black's Law Dictionary- as opposed to the prior edition cited in Rodriguez -defined "child abuse" as "[i]ntentional or neglectful physical or emotional harm inflicted on a child, including sexual molestation."Id. (quoting Abuse , BLACK'S LAW DICTIONARY (8th ed. 2004) ).2
Based on these considerations, the BIA "interpret[ed] the term 'crime of child abuse' broadly to mean any offense involving an intentional, knowing, reckless, or criminally negligent act or omission that constitutes maltreatment of a child or that impairs a child's physical or mental well-being, including sexual abuse or exploitation." Id. at 512. The BIA went on to note that:
At a minimum, this definition encompasses convictions for offenses involving the infliction on a child of physical harm, even if slight; mental or emotional harm, including acts injurious to morals; sexual *985abuse, including direct acts of sexual contact, but also including acts that induce (or omissions that permit) a child to engage in prostitution, pornography, or other sexually explicit conduct; as well as any act that involves the use or exploitation of a child as an object of sexual gratification or as a tool in the commission of serious crimes, such as drug trafficking.
Id. (emphasis added). Significantly, however, the BIA did not address whether a crime of child abuse required actual injury to a child. A concurring opinion noted this very fact: "It should be noted that, broad though the definition is, it is unclear whether it extends to crimes in which a child is merely placed or allowed to remain in a dangerous situation, without any element in the statute requiring ensuing harm, e.g., a general child endangerment statute, or selling liquor to an underage minor, or failing to secure a child with a seatbelt." Id. at 518 n.2 (Pauley, concurring).
C. Pacheco Fregozo
We had our first opportunity to address Velazquez 's definition of a crime of child abuse in Pacheco Fregozo v. Holder , 576 F.3d 1030, 1033 (9th Cir. 2009). Ernesto Pacheco Fregozo had been arrested for driving under the influence of alcohol with two children in his car and convicted of misdemeanor child endangerment under California Penal Code § 273a(b). Id. at 1033-34. The BIA held in an unpublished opinion-issued before it decided Velazquez -that Pacheco Fregozo's conviction was categorically a crime of child abuse under the "cruelty" definition cited in Rodriguez . Id. at 1034.
In granting Pacheco Fregozo's petition for review, we acknowledged that the BIA had recently interpreted "a crime of child abuse" in Velazquez but held that it was unnecessary to remand for the BIA to apply Velazquez in the first instance. Id. at 1036 ("We are convinced that a remand is not necessary in this case. Aside from according Chevron deference to the Board's interpretation of a 'crime of child abuse' in the INA, which we do, we review de novo whether the California conviction is a removable offense."). We interpreted Velazquez as requiring conduct that "actually inflict[s] some form of injury on a child," without explaining where the BIA's decision imposed such a requirement. Id. at 1037. Based on that questionable reading of Velazquez , we then concluded that California Penal Code § 273a(b) was not a categorical match for § 1227(a)(2)(E)(i) because it reached conduct that "creates only potential harm to a child; no actual injury to a child is required." Id. at 1036-38.
We also held that § 273a(b) was not a categorical match for a crime of child abuse for an independent reason. Unlike the felony provision in the same statute, § 273a(b) does not require "any particular likelihood of harm to a child":
[U]nlike the analogous felony provision, California Penal Code section 273a(a), the misdemeanor provision [in section 273a(b) ] does not require that the perpetrator actually endanger the health or safety of the child at all-the misdemeanor provision applies where the child's health or safety "may be endangered" by the circumstances. The BIA's definition of "child abuse," requiring some actual injury to a child, does not reach conduct that merely could place a child's health and safety at risk.
.... Negligent or intentional conduct that places a child in situations in which serious harm is imminently likely could fairly constitute "impairment" of a child's well-being. The misdemeanor California statute under which Pacheco was convicted, however, does not conform to the alternative definition, as it applies "under circumstances or conditions *986other than those likely to produce great bodily harm or death." Cal. Penal Code § 273a(b) (emphasis added).
Id. at 1037-38. This alternative basis for our holding in Pacheco Fregozo appears to have been in tension with the first, as it implied that Velazquez did not require actual injury but only actual endangerment . At the very least, our discussion in this regard suggested that, even though misdemeanor child endangerment under § 273a(b) was not a categorical match for a crime of child abuse as defined in Velazquez , felony child endangerment under § 273a(a) likely was.
D. Soram
The following year, the BIA responded to our decision in Pacheco Fregozo . In Matter of Soram , the BIA "respectfully clarif[ied] that the term 'crime of child abuse,' as described in Velazquez-Herrera is not limited to offenses requiring proof of injury to the child":
[T]he United States Court of Appeals for the Ninth Circuit has issued a decision addressing this question. Fregozo v. Holder , 576 F.3d 1030 (9th Cir. 2009). The court interpreted our decision in Matter of Velazquez-Herrera to require that a child must actually be injured for a crime to constitute child abuse. ... However, as indicated above, we did not directly address this issue in Velazquez-Herrera . We do so now and find no convincing reason to limit offenses under section 237(a)(2)(E) of the Act to those requiring proof of actual harm or injury to the child.
25 I. & N. Dec. 378, 380-81 (BIA 2010). At the same time, the BIA also clarified that "the phrase 'a crime of child abuse, child neglect, or child abandonment' in section 237(a)(2)(E)(i) of the Act denotes a unitary concept and [its] broad definition of child abuse [in Velazquez ] describes this entire phrase." Id. at 381.
The BIA reasoned that "[a]s recently as July 2009, some 38 States [and several territories] ... included in their civil definition of 'child abuse,' or 'child abuse or neglect,' acts or circumstances that threaten a child with harm or create a substantial risk of harm to a child's health or welfare." Id. at 382. In this respect, the BIA noted that "endangering a child can reasonably be viewed as either abuse or neglect" and that "some States include child endangerment in their definition of 'child abuse,' while a number of others consider it 'child abuse or neglect.' " Id. at 381. A concurring opinion added that: "A review of the criminal child abuse statutes of the various States reveals that as of September 1996, a majority of States-28-had criminal provisions punishing child endangerment offenses as part of their criminal child abuse statutes." Id. at 388 (Filppu, concurring).
The BIA also acknowledged that, although a crime of child abuse, neglect, or abandonment required only a risk of injury to a child, the risk had to be sufficiently great-thus placing an outer limit on its broad definition. Id. at 382-83. The BIA noted that different state statutes used different terms (e.g., "realistic," "serious," or "substantial") to describe the requisite level of risk, and that even statutes with similar terms were interpreted differently by various state courts. Id. Rather than attempt to analyze "the myriad State formulations of endangerment-type child abuse offenses" all at once, the BIA decided a case-by-case analysis was appropriate "to determine whether the risk of harm by the endangerment-type language ... is sufficient to bring an offense within the definition of 'child abuse' under the Act." Id. at 383.
Contrary to what the dissent argues, Dissenting Op. at 997, Soram did not reflect a change in the BIA's position but *987rather addressed an issue that Velazquez had left open. The concurring opinion in Velazquez had expressly noted that whether a crime of child abuse required actual injury to a child remained an open question. Moreover, Soram responded to our court's misinterpretation of the BIA's prior decision. Despite what we said in Pacheco Fregozo , the BIA's decision in Velazquez nowhere intimated that child abuse required actual injury. At most, it noted that, "[a]t a minimum," child abuse included physical harm "even if slight," as well as mental or emotional harm, acts injurious to morals, and use of a child "as an object of sexual gratification." Velazquez , 24 I. & N. Dec. at 512. The BIA's correction of our misinterpretation was not a change in position but rather a clarifying, gap-closing measure.
III. CHEVRON DEFERENCE
We apply Chevron 's two-step framework to the BIA's construction of the INA in precedential decisions. See, e.g. , Reyes v. Lynch , 842 F.3d 1125, 1133 (9th Cir. 2016). "Under the first step, we determine whether Congress has directly spoken to the precise question at issue." Perez-Guzman v. Lynch , 835 F.3d 1066, 1073-74 (9th Cir. 2016) (quotation marks omitted). If "Congress has not spoken to a particular issue or the statute is ambiguous," we pass to the second step and consider the agency's interpretation of the statute. Id. If the "agency's construction is reasonable, Chevron requires a federal court to accept the agency's construction of the statute, even if the agency's reading differs from what the court believes is the best statutory interpretation." Id. (quoting Nat'l Cable & Telecomms. Ass'n v. Brand X Internet Servs. , 545 U.S. 967, 980, 125 S.Ct. 2688, 162 L.Ed.2d 820 (2005) ).
A. Chevron Step One
Section 1227(a)(2)(E)(i) states that "[a]ny alien who at any time after admission is convicted of a crime of domestic violence, a crime of stalking, or a crime of child abuse, child neglect, or child abandonment is deportable." Unlike the term "crime of domestic violence," no part of the phrase "a crime of child abuse, child neglect, or child abandonment" is defined in the INA. There are no federal crimes of child abuse, neglect, or abandonment to provide analogous definitions, and unlike certain common-law crimes like burglary or assault, there are no widely accepted definitions of child abuse, neglect, or abandonment.
Section 1227(a)(2)(E)(i) 's language is broad and susceptible to multiple interpretations. Every circuit court to have considered it has noted its ambiguity. See Florez , 779 F.3d at 211 ("[W]e have little trouble concluding that the statutory provision is ambiguous."); Ibarra , 736 F.3d at 910 (rejecting the BIA's interpretation but only after acknowledging that "the statutory language is ambiguous"). We agree and therefore pass to step two.
B. Chevron Step Two
Step two is where our sister circuits have split. In Florez , the Second Circuit held that the BIA's interpretation was reasonable and entitled to deference. 779 F.3d 207.3 Similar to the instant case, Nilfor Yosel Florez had been convicted of child endangerment under New York law for driving under the influence with children *988in his car and had been ordered removed under § 1227(a)(2)(E)(i). Id. at 208. The Second Circuit reasoned that, as of 1996 when Congress passed IIRIRA, "at least nine states had crimes called 'child abuse' (or something similar) for which injury was not a required element." Id. at 212. Although "even more states used a definition that did require injury," courts must not "look[ ] for the best interpretation, or the majority interpretation-only a reasonable one." Id. The Second Circuit concluded that the BIA acted reasonably in adopting a definition of child abuse "consistent with the definitions used by the legislatures of Colorado, Kentucky, Nebraska, New Jersey, New Mexico, North Carolina, Ohio, Oklahoma, and Virginia." Id. Moreover, Black's Law Dictionary offered a definition of "child abuse" that did not require injury. Id. (citing Abuse , BLACK'S LAW DICTIONARY (9th ed. 2009) (defining "child abuse" as "[a]n act or failure to act that presents an imminent risk of serious harm to a child") ). Finally, Soram 's requirement of a sufficiently high risk of harm to a child ensured that the BIA's treatment of child-endangerment statutes would remain "within the realm of reason." Id.
In Ibarra , the Tenth Circuit reached the opposite conclusion. The facts were extraordinarily sympathetic: Elia Ibarra had unintentionally left her children home alone one evening while she was at work and, as a result, had been convicted of "child abuse-negligence-no injury" under Colorado law. 736 F.3d at 905. In subsequent removal proceedings, Ibarra conceded removability but sought cancellation of removal. Id. The BIA held her ineligible for cancellation on grounds that her conviction was a crime of child abuse, neglect, or abandonment. Id. at 906. The Tenth Circuit criticized the BIA for relying "primarily on definitions of 'child abuse' and 'child neglect' from civil, not criminal, law." Id. at 912. The court held that the BIA should have identified "the majority of states' consensus as of [the year Congress enacted IIRIRA] ... to find the generic meaning of criminal child abuse." Id. at 914 (quotation marks omitted). The court then did its own fifty-state survey of state criminal laws, concluding that the majority of states (thirty-three) required a higher mens rea than criminal negligence for conviction of an offense not involving actual injury to a child. Id. at 915. On this basis, the court rejected the BIA's interpretation of a crime of child abuse, neglect, or abandonment as unreasonable. Id. at 915-16.
We agree with the Second Circuit and likewise hold that the BIA's interpretation of § 1227(a)(2)(E)(i) is reasonable and entitled to deference. Velazquez and Soram are careful decisions, and although they may not represent the only permissible construction of the statutory language at issue, the BIA was not unreasonable for the same reasons identified by the Second Circuit. That the BIA's interpretation does not require intentional or actual injury to a child-the critical distinctions in this case-would perhaps be troubling if the BIA were only interpreting the term "child abuse," but the term "child neglect" surely admits of such conduct. See Neglect , BLACK'S LAW DICTIONARY (10th ed. 2014) (defining "child neglect" as "[t]he failure of a person responsible for a minor to care for the minor's emotional or physical needs;" and defining "willful neglect" as "intentional or reckless failure to carry out a legal duty, esp. in caring for a child").
Even as we agree with the Second Circuit, we decline to follow the Tenth Circuit's reasoning because we find it flawed. First, there is no inherent problem in the BIA relying partly on civil statutes to understand the phrase "a crime of child abuse, child neglect, or child abandonment." It would be unreasonable for the *989BIA to interpret that phrase, which refers to one who is "convicted of a crime," to cover a purely civil action, such as child neglect proceedings brought by a state's child protective services. We thus agree with the dissent that it would be improper for the BIA to use "a civil definition for a crime." Dissenting Op. at 1003; see also id. at 999, 1002-03. But that is not what the BIA did. Rather, the BIA used civil definitions to inform its understanding of which convictions are crimes of child abuse, neglect, or abandonment, and that is not unreasonable.
A phrase such as "child neglect" surely can serve both civil and criminal purposes, and there is nothing unreasonable in trying to find a definition that would serve both simultaneously. That the BIA looked to civil definitions of abuse and neglect does not detract from the fact that an alien's deportability depends on having been convicted of a crime. The only question is what crimes constitute child abuse, neglect, or abandonment, and for that the BIA was well within reason to look to civil definitions. In fact, civil law makes a particularly apt comparison here: parental rights adjudicated in civil child neglect proceedings implicate serious due process concerns, and courts have sometimes referred to terminating parental rights as a "civil death penalty," see, e.g. , In re K.A.W ., 133 S.W.3d 1, 12 (Mo. 2004) ; In re K.D.L. , 118 Nev. 737, 58 P.3d 181, 186 (2002), and have required the state to satisfy a heightened burden of proof before terminating those rights, see, e.g. , In re E.A.F. , 424 S.W.3d 742, 746 (Tex. Ct. App. 2014) ; In re B.A.C. , 317 S.W.3d 718, 723-24 (Tenn. Ct. App. 2009).
Second, there is no requirement that the BIA interpret a generic offense in the INA to conform to how the majority of states might have interpreted that term at the time of amendment. That is one reasonable aid to interpreting statutes, but it is not the only reasonable method for doing so.4 Contrary to the Tenth Circuit's argument, the Supreme Court's decision in Taylor has no bearing on this issue. See Ibarra , 736 F.3d at 913 (" Taylor instructs courts to find that 'generally accepted contemporary meaning' by looking to 'the *990criminal codes of most States.' "). In Taylor , the Court interpreted the word "burglary" in a federal sentence enhancement statute and determined "that Congress meant by 'burglary' the generic sense in which the term is now used in the criminal codes of most States." 495 U.S. at 598, 110 S.Ct. 2143. The Court relied on the "generally accepted contemporary meaning" and looked to elements common to the state definitions. Id. at 596, 598, 110 S.Ct. 2143. The Court was not, however, reviewing an agency's interpretation of an ambiguous statute and did not purport to offer any guidance to lower courts employing Chevron 's two-step framework. Nothing in Taylor requires that the BIA conduct a fifty-state survey and agree with the majority approach among the states every time it interprets an ambiguous generic offense in the INA. And recently the Court has referred to this methodology as an "aid [to] our interpretation ... offering useful context." Esquivel-Quintana , 137 S.Ct. at 1571 n.3. The BIA's statutory construction is not constrained to a mere head-counting exercise.
Taylor 's methodology worked in context: "burglary" is a well-recognized legal term in the common law, the MPC, and state law.5 By contrast, child abuse, neglect, and abandonment are not common law crimes; they are twentieth-century crimes. According to Black's Law Dictionary , the first prosecution for child abuse was in 1874, when "[a]n eight-year-old girl named Mary Ellen was found to have been severely abused. Her abusers were prosecuted under the law for prevention of cruelty to animals since no law protecting children then existed ." Abuse , BLACK'S LAW DICTIONARY (10th ed. 2014) (emphasis added). Similarly, the MPC offers virtually no clue to the terms in § 1227(a)(2)(E)(i). See MPC § 230.4 (Endangering Welfare of Children). The notes to the MPC explain: "The crimes of endangering the welfare of children and persistent nonsupport represent substantial modification and consolidation of offenses that were variously treated in prior law and that have also received widely differing treatment in recent revisions." MPC Pt. II, Art. 230, Refs. & Annos. (emphasis added).
Moreover, states have developed different and varied terms in this area, thus complicating Congress's task in describing what crimes involving children count as crimes of child abuse, neglect, or abandonment. Indeed, it seems that Congress purposefully employed the overlapping concepts of child abuse, neglect, and abandonment to denote a broad array of crimes. As a BIA member's concurring opinion in Velazquez noted, "crimes of child neglect or abandonment are a subset of 'child abuse' and, although technically redundant, were likely inserted by Congress to assure coverage of such crimes, however denominated by the State ." 24 I. & N. Dec. at 519 (Pauley, concurring)
*991(emphasis added). In short, the lack of a common source for the terms and the varied ways in which states have addressed the problem of child abuse-however it is denominated-only reinforces the ambiguity in what constitutes a crime of child abuse, neglect, or abandonment. It is precisely because of that ambiguity that we must proceed to Chevron step two, where there is no single methodology for resolving ambiguity in a statute.
Third, the Tenth Circuit's ambitious, fifty-state survey was itself problematic. The court categorized state laws according to the minimum mens rea they required for conviction of a crime not resulting in injury to a child.6 It found twenty-seven jurisdictions requiring "a minimum mens rea of knowingness or intent for crimes not appearing to require a resulting injury to the child;" six requiring "a minimum mens rea of criminal negligence for crimes not requiring a resultant injury;" eleven requiring "criminal negligence" or something less for crimes not a resultant injury; and five that had no clear standard. Id. at 915, 918-21. The court concluded that, because "a clear majority of states did not criminalize such conduct when it was committed with only criminal negligence and resulted in no injury," the BIA's construction of § 1227(a)(2)(E)(i) fell "outside the interpretive 'gap' left by Congress." Id. at 918.
The Tenth Circuit's methodology fails even under its own rules, and we need look no further than the California statute at issue here. According to the Tenth Circuit, § 273a(a)"required a minimum mens rea of knowingness or intent for crimes not appearing to require a resulting injury to the child." Ibarra , 736 F.3d at 918. The Tenth Circuit therefore included California in its "majority" of states that supposedly contradicted the BIA's interpretation. According to the California Supreme Court, however, California Penal Code § 273a(a) requires only a minimum mens rea of "criminal negligence." People v. Valdez , 27 Cal.4th 778, 118 Cal.Rptr.2d 3, 42 P.3d 511, 517 (2002) ("[F]or 25 years, the lower courts have identified criminal negligence as the relevant standard of culpability for section 273a..., and this court has applied that same standard."). The Tenth Circuit's mistake in this regard reinforces that a fifty-state survey-particularly one of difficult to discern mens rea categories-is not the only reasonable way to interpret the INA.
Fourth, an agency need not give an answer to every conceivable question in one decision. The BIA noted in Soram that different state statutes employ different language regarding their requisite level of risk and that even similar statutes have been interpreted differently by various state courts. 25 I. & N. Dec. at 382-82. Further, the BIA held that the risk of injury to a child must be sufficiently great, and it carefully explained why the Colorado statute at issue met that requirement. Id. at 383-86. It was reasonable for the BIA to decline to analyze all at once "whether the myriad State formulations of endangerment-type child abuse offenses come within the ambit of 'child abuse' under *992... the Act." Id. at 383. Indeed, the Tenth Circuit's flawed fifty-state survey shows the danger of a contrary approach.7
Finally, this is not a case of the BIA changing positions without explaining its rationale for doing so. For one, the BIA did not change its position: Rodriguez 's brief discussion of § 1227(a)(2)(E)(i) was dictum; Velazquez gave the first precedential interpretation of § 1227(a)(2)(E)(i) but left the issue of actual injury undecided; and Soram merely filled the gap that Velazquez left open. The dissent's strained reading of Rodriguez and Velazquez tries to hold the BIA to an interpretation that was never in fact the agency's position. More importantly, even if one thought the BIA had changed its position, the BIA has explained its reasoning. See Brand X , 545 U.S. at 981, 125 S.Ct. 2688. It is only an "[u]nexplained inconsistency" that is a reason for finding an interpretation unreasonable. Id. ; Encino Motorcars, LLC v. Navarro , --- U.S. ----, 136 S.Ct. 2117, 2125-26, 195 L.Ed.2d 382 (2016). Indeed, in Chevron itself, the Supreme Court "deferred to an agency interpretation that was a recent reversal of agency policy." Brand X , 545 U.S. at 981, 125 S.Ct. 2688 (citing Chevron , 467 U.S. at 857-58, 104 S.Ct. 2778 ). The BIA's interpretation in Soram was a response to our decision in Pacheco Fregozo and gave sufficient reason for why the agency believed a crime of child abuse, neglect, or abandonment did not require proof of actual injury. This was not a change in the BIA's position, but even if it had been, it was suitably explained.8
In sum, we hold that the BIA's interpretation of a crime of child abuse, neglect, or abandonment in Velazquez and Soram is a reasonable construction of ambiguous statutory language. We therefore join the Second Circuit in deferring to the BIA's interpretation.
IV. THE CATEGORICAL APPROACH
We next consider whether Martinez-Cedillo's conviction under California Penal Code § 273a(a) is categorically a crime of child abuse, neglect, or abandonment, as interpreted by the BIA. We apply Skidmore deference to the BIA's nonprecedential holding in this case that *993§ 273a(a) is categorically such a crime. See Marmolejo-Campos v. Holder , 558 F.3d 903, 909 (9th Cir. 2009). "Under Skidmore , the measure of deference afforded to the agency varies depending upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control." Id. (alteration and quotation marks omitted).
Under the categorical approach, we look "not to the facts of the particular prior case" but to whether "the state statute defining the crime of conviction" categorically fits within the "generic" federal offense. Moncrieffe v. Holder , 569 U.S. 184, 133 S.Ct. 1678, 185 L.Ed.2d 727 (2013). The relevant section of the California statute states:
Any person who, under circumstances or conditions likely to produce great bodily harm or death, willfully causes or permits any child to suffer, or inflicts thereon unjustifiable physical pain or mental suffering, or having the care or custody of any child, willfully causes or permits the person or health of that child to be injured, or willfully causes or permits that child to be placed in a situation where his or her person or health is endangered, shall be punished by imprisonment in a county jail not exceeding one year, or in the state prison for two, four, or six years.
Cal. Penal Code § 273a(a). As noted above, the California Supreme Court has interpreted § 273a(a) to cover criminally negligent conduct resulting in risk of "great bodily harm or death" to a child. Valdez , 118 Cal.Rptr.2d 3, 42 P.3d at 517 ; see also Ramirez v. Lynch , 810 F.3d 1127 (9th Cir. 2016).9
Even before the BIA decided Soram , our decision in Pacheco Fregozo strongly suggested that felony child endangerment under § 273a(a) was categorically a crime of child abuse, neglect, or abandonment.10 576 F.3d at 1037-38. After Soram , the result is all the more clear. Unlike § 273a(b), § 273a(a) requires criminally negligent conduct under "conditions likely to produce great bodily harm or death" to a child. See id. ; People v. Jaramillo , 98 Cal.App.3d 830, 159 Cal.Rptr. 771 (1979) (holding that § 273a(a) is "intended to protect a child from an abusive situation in which the probability of serious injury is great").11 This high degree of risk brings the crime completely within the ambit of the BIA's broad interpretation. See *994Soram , 25 I. & N. Dec. at 378 ; Velazquez-Herrera , 24 I. & N. Dec. at 512.
V. RETROACTIVITY
Martinez-Cedillo argues that he pled guilty of violating § 273a(a) before the BIA decided Soram and that therefore Soram should not apply to his conviction. We apply the five-factor Montgomery Ward test to address "the situation when a 'new administrative policy [is] announced and implemented through adjudication.' " Garfias-Rodriguez v. Holder , 702 F.3d 504, 518 (9th Cir. 2012) (en banc) (quoting Montgomery Ward & Co. v. FTC , 691 F.2d 1322, 1328 (9th Cir. 1982) ). The five factors are:
(1) whether the particular case is one of first impression, (2) whether the new rule represents an abrupt departure from well established practice or merely attempts to fill a void in an unsettled area of law, (3) the extent to which the party against whom the new rule is applied relied on the former rule, (4) the degree of the burden which a retroactive order imposes on a party, and (5) the statutory interest in applying a new rule despite the reliance of a party on the old standard.
Id. Although the Montgomery Ward test was developed in the context of an agency overturning its own rule, it also applies where, as here, an agency disagrees with a court's decision. Id.
The first factor is generally not "well suited to the context of immigration law" and does not weigh either for or against retroactivity. Id. at 521. The second and third factors "are closely intertwined" and do support retroactivity here. Id. The BIA's decision in Soram was not an abrupt departure from a well established practice but rather a clarification of a prior uncertainty. As explained above, a concurring opinion in Velazquez expressly noted that whether § 1227(a)(2)(E)(i) required actual injury was an open question. Soram thus "fill[ed] a void in an unsettled area of law" and cannot have come as "a complete surprise" to Martinez-Cedillo. Id. at 521-22. Although the fourth factor favors non-retroactive application because deportation is unquestionably a substantial burden, the fifth factor cuts in the other direction because "non-retroactivity impairs the uniformity of a statutory scheme, and the importance of uniformity in immigration law is well established." Id. at 523. In sum, the second, third, and fifth factors of the Montgomery Ward analysis favor retroactive application of Soram , and the BIA properly applied Soram to Martinez-Cedillo's conviction in this case.12
VI. REQUEST FOR A CONTINUANCE
Finally, Martinez-Cedillo challenges the denial of his request for a continuance. An IJ may grant a continuance for "good cause shown."
*9958 C.F.R. § 1003.29. "We review the denial of a continuance for an abuse of discretion." Id. Here, Martinez-Cedillo requested a continuance based on his pending visa application. The IJ denied his request based on the untimeliness of the request, the remoteness of Martinez-Cedillo's priority date for a visa, and the speculative nature of his eligibility for adjustment of status, and the BIA affirmed for the same reasons. There was no abuse of discretion.
VII. CONCLUSION
For the foregoing reasons, we DENY the petition for review.