"I can't tell you precisely what a specific CEO should make, any more than I can tell you what a top-performing Major League Baseball shortstop should make," Freeman said in an emailed statement.
Since the AP began tracking CEO pay five years ago, the numbers have seesawed. Pay climbed in 2007, fell during the recession in 2008 and 2009 and then jumped again in 2010.
To determine 2011 pay packages, the AP used Equilar data to look at the 322 companies in the S&P 500 that had filed statements with federal regulators through April 30. To make comparisons fair, the sample includes only CEOs in place for at least two years.
Among the AP's other findings:
— David Simon, CEO of Simon Property, which operates malls around the country, is on track to be the highest-paid in the AP survey, at $137 million. That was almost entirely in stock awards that could eventually be worth $132 million, some of which won't be redeemable until 2019. The company said it wanted to make sure Simon wasn't lured to another company. He has been CEO since 1995; his father and uncle are Simon Property's co-founders.
This month, Simon Property's shareholders rejected Simon's pay package by a large margin: 73 percent of the votes cast for or against were against.
But the company doesn't appear likely to change the 2011 package. After the shareholder vote, it released a statement saying that "we value our stockholders' input" and would "take their views into consideration as (the board) reviews compensation plans for our management team." But it also said that Simon's performance had been stellar and it needed to pay him enough to keep him in the job.
Simon's paycheck looks paltry compared with that of Apple CEO Tim Cook, whose pay package was valued at $378 million when he became CEO in August. That was almost entirely in stock awards, some of which won't be redeemable until 2021, so the value could change dramatically. Cook wasn't included in the AP study because he is new to the job.
— Of the five highest-paid CEOs, three were also in the top five the year before. All three are in the TV business: Leslie Moonves of CBS ($68 million); David Zaslav of Discovery Communications, parent of Animal Planet, TLC and other channels ($52 million); and Philippe Dauman of Viacom, which owns MTV and other channels ($43 million).
— About two in three CEOs got raises. For 16 CEOs in the sample, pay more than doubled from a year earlier, including Bank of America's Brian Moynihan (from $1.3 million to $7.5 million), Marathon Oil's Clarence Cazalot Jr. (from $8.8 million to $29.9 million) and Motorola Mobility's Sanjay Jha (from $13 million to $47.2 million).
— CEOs running health-care companies made the most ($10.8 million). Those running utilities made the least ($7 million).
— Perks and other personal benefits, such as hired drivers or personal use of company airplanes, rose only slightly, and some companies cut back, saying they wanted to align their pay structure with "best practices."
Military contractor General Dynamics stopped paying for country club memberships for top executives, though it gave them payments equivalent to three years of club fees to ease "transition issues" caused by the change.
The typical pay of $9.6 million that Equilar calculated is the median value, or the midpoint, of the companies used in the AP analysis. In other words, half the CEOs made more and half less.
To value stock awards and stock options, the AP used numbers supplied by the companies. Those figures are based on formulas the companies use to estimate what the stock and options will eventually be worth when a CEO receives the stock or cashes in the options.
Stock awards are generally valued based on the stock's current price. Stock options are valued using company estimates that take into account the stock's current price, how long until the CEO can cash the options in, how the stock price is expected to move before then, and expected dividends. Estimates don't generally take inflation into account.