Paper:
The performance of deep neural networks is often attributed to their automated, taskrelated feature construction. It remains an open question, though, why this leads to solutions with good generalization, even in cases where the number of parameters is larger than the number of samples. Back in the 90s, Hochreiter and Schmidhuber observed that flatness of the loss surface around a local minimum correlates with low generalization error. For several flatness measures, this correlation has been empirically validated. However, it has recently been shown that existing measures of flatness cannot theoretically be related to generalization: if a network uses ReLU activations, the network function can be reparameterized without changing its output in such a way that flatness is changed almost arbitrarily. This paper proposes a natural modification of existing flatness measures that results in invariance to reparameterization. The proposed measures imply a robustness of the network to changes in the input and the hidden layers. Connecting this feature robustness to generalization leads to a generalized definition of the representativeness of data . With this, the generalization error of a model trained on representative data can be bounded by its feature robustness which depends on our novel flatness measure.

Review:
This paper describes a connection between flatness of minima and generalization in deep neural networks. The authors define a concept called "feature-robustness" and show that it is related to flatness. This is derived through a straightforward observation that perturbations in feature space can be recast as perturbations of the model in parameter space. This allows the authors to define a (layerwise) flatness measure for minima in deep networks (this layerwise flatness measure is also invariant to rescalings of the layers in neural networks with positively homogenous activations). The authors combine their notion of feature robustness with epsilon representativeness of a function to connect flatness to generalization. They present a few empirical evaluations on CIFAR10 and MNIST.
I believe this paper is able to once again confirm the relationship between flatness and generalization in an empirical manner with their layerwise measure of flatness. I am not so convinced about the theoretical justification that they claim to provide and thus do not recommend acceptance.
Theory - The key theorem relating generalization and flatness is Theorem 10 which says that if a compositional model is feature robust and the output of the first component is an epsilon-representative for the second component, then the compositional model will generalize. While this is interesting, it is not clear to me that this guarantees generalization for deep neural networks. This result only talks about feature robustness and representativeness for a particular layer. If a deep network has many layers, will the feature robustness layers closer to the input guarantee feature robustness at deeper layers? That might require a further unit operator norm constraint on the layer operator, which is a restriction on the types of weights that can be used. If a sample is epsilon representative at one layer, what is required for the next layer to be epsilon representative for the rest of the deep network? This seems to be a missing step in relating flatness/feature robustness of a layer to the generalization of the whole network.
Another idea that I think arises from Theorem 10 is that the flatness of loss landscapes is important when you have learning problems where the hypothesis class is compositional. While flatness is only spoken of in the case of deep neural networks, can we identify the same phenomenon in other problems? I would encourage the authors to try and identify another model in which the flatness-generalization relationship exists (even empirical evidence would suffice for now). This would strengthen the case for studying flatness and biasing optimization towards flatter solutions in the case of deep networks.
Experiments - This section seems to be pretty rudimentary, I would like to see more results on different kinds of network architectures (VGG? Inception? AlexNet?), more datasets (KMNIST? Fashion MNIST? SVHN?), and possibly more repetitions. At one point the authors mention that they declare a minimum has been reached if the training loss is < 0.07. Atleast on CIFAR10 and MNIST it is possible to achieve training loss <1e-4 so am not sure if the networks that the authors are testing are minima at all (It is important for them to be minima since the flatness measure is only defined at minima). Can the authors also identify more situations other than large batch vs small batch training that would lead them to obtain flatter/sharper minima?
The authors also claim that measuring generalization using test error is flawed, but do not provide details about their method of measuring generalization. I would want to see these details and a more thorough discussion of why measuring generalization through test error is flawed.
While this is an interesting paper, I do not believe it is ready for acceptance at ICLR 2020.