Is advancement of a felonious purpose an element of the felony-murder special-circumstance?

To begin with, I believe that advancement of an independent felonious purpose is an element of the felony-murder special-circumstance and as such should have been instructed on in connection with each of the felony-murder special-circumstances alleged in this case. We held as much in People v. Green (1980) 27 Cal.3d 1, 61-62, 164 Cal.Rptr. 1, 609 P.2d 468. The majority choose not to dispute this point and, in my view, simply cannot do so.