“…Instead of using y ∈ S(x) as a constraint in (BP), Outrata [25] proposed to replace it with f (x, y) − V (x) = 0, y ∈ Y (x) where V (x) := inf y∈Y (x) f (x, y) is the value function of the lower level program for a numerical consideration. This so-called value function approach was further used in Ye and Zhu [32] and later in other papers such as [7,8,21,22,23,24] to derive various necessary optimality conditions under the partial calmness condition. The partial calmness condition for the value function reformulation of the bilevel program, however, is a very strong assumption.…”