Both his subordinates earned more than Roberts, too. CBS boss Leslie Moonves was paid $62.1 million to head the nation's top-rated broadcast-TV network, first-run home of The Big Bang Theory.
Viacom head Philippe Dauman earned $33.5 million running its cable channels, which include MTV and Comedy Central.
Walt Disney Co.'s Robert Iger has taken heat from a California teachers pension fund for his $40.2 million compensation package in 2012. The California State Teachers' Retirement System, opposed to Iger's pay, voted its 5.3 million Disney shares in protest at the company's annual shareholders meeting in March.
Rupert Murdoch, chief executive at ethics-challenged News Corp., which owns the Fox entertainment businesses, was compensated $30 million last year. Discovery Communications Inc. chief executive David M. Zaslav was paid $49.9 million - Discovery's cable channels include Animal Planet, Discovery, TLC, and Investigation Discovery.
"Labor markets are competitive," said Robert Daines, a Stanford University law professor and expert in executive compensation, and Comcast and others in the entertainment industry have to match the compensation at peer companies.
He added that compensation is a function of financial size, and that entertainment companies - with portfolios of cable channels, Internet websites, sports rights, and production studios - are now very large organizations.
In its regulatory statement, Comcast says it considered three categories of companies when determining executive pay: entertainment companies, telecommunications companies, and large diversified companies.
The entertainment companies were CBS, News Corp., Time Warner Inc., Viacom, and Disney. The telecommunications were AT&T Inc., DirecTV, Sprint Nextel Corp., Time Warner Cable Inc., and Verizon Communications Inc. The diversified companies included DuPont, Boeing, and American Express.
Stephen Burke, a Comcast executive vice president and the head of NBCUniversal, was the second-highest-compensated executive at Comcast in 2012, earning $26.3 million.
His compensation was comparable to that of two peer entertainment bosses: Jeffrey Bewkes, the chief executive officer and chairman at Times Warner Inc., who was paid $25.9 million in 2012, and Chase Carey, the No. 2 executive at News Corp. after Murdoch, who was compensated $24.8 million.
Though Comcast has a big entertainment business with NBCUniversal, its most consistent profits flow through the cable division, with 22 million cable-TV and 20 million Internet subscribers. Neil Smit, who heads this division, was compensated $18.3 million in 2012.
Two companies comparable to Comcast's cable division are Time Warner Cable and Verizon Communications, both of which operate TV- and Internet-distribution businesses. They compensate their top executives between $17 million and $18 million.
The other top-paid executives at Comcast in 2012 were chief financial officer Michael Angelakis at $23.2 million and executive vice president David Cohen, $15.9 million.
Mark Cooper, director of research at the Consumer Federation of America, said of Roberts: "You can say he doesn't make as much as media moguls, but most of the profits in his career came from a very different business, cable TV."
Contact Bob Fernandez at 215-854-5897 or firstname.lastname@example.org or follow on Twitter @bobfernandez1.