[cc65] "thought experiment", would it be possible to write a c64-kernal replacement with cc65? [scanned]

Hi Folks!

Its just a thought experiment that i had recently, would it be possible
to write a kernal replacement with just cc65, without inline asm and
without any libary? 
Or is the C overhead too big for an 8-bit kernal?
If the overhead is too big, what would be need to be done to cc65 to
make this possible?
I wouldnt aim compatibility with this, but some sort of modern OS on an
8-bitter.

Readya,
Markus

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