As part of unpublished Turner research informed by local knowledge, Dr Bernard Richards1 hesitated to concur with previous commentators that this is a Dudley view. Inverted relative to the sketchbook’s foliation, the apparent presence of two church spires would suggest that the subject may be Birmingham (Dudley’s only spire being St Thomas’s), despite falling between various identified Dudley views. Folio 47 recto (D22411) may show Birmingham and 49 recto (D22415) certainly does. The chimneys in the middle distance and the bridge on the left may indicate a canal-side setting; compare the Birmingham views in the contemporary Kenilworth sketchbook, for example Tate D21997 and D21998 (Turner Bequest CCXXXVIII 13a, 14).
Conversation with the author, 14 May 2013.