I was doing something similar for the entire OS a few years ago: cosmopolinux, a distribution of cosmopolitan binaries: https://github.com/csdvrx/cosmopolinux
My idea was to replace the WSL binaries to have a Linux distribution living on C:\, but that could also be booted baremetal if you didn't want to use Windows
I had to put together a multi stage init system for that: if you get the ISO, you can put in on a thumbdrive and boot it: https://gitlab.com/csdvrx/cosmopolinux
The only difference between them is the kernel and the filesystem: the github NTFS has a firecracker linux kernel, the gitlab ISO has a regular kernel with many modules.
I wanted to do a full NTFS solution but I couldn't find a bootloader I liked that would support booting from a NTFS partition.
Booting from an ISO was simpler and faster.