The national airline of Abu Dhabi said that it "receives no government subsidies or sovereign guarantees" and no discounted fuel or airport services.
The response, submitted to the US departments of state, transportation and commerce, emphasised "the many benefits" of increased competition for US consumers, workers and carriers as well as trade and tourism.
"Our story is one of an airline that has chosen to challenge the global status quo, bringing new competition to markets that have for too long been dominated by the major legacy airlines," Etihad CEO James Hogan said.
"Let's keep the skies open."
Also Read
In March, American Airlines, Delta Airlines and United Airlines, along with US airline labour groups, accused Gulf carriers of enjoying interest-free loans, subsidised airport charges, government protection on fuel losses, and below-market labour costs that are considered unfair subsidies by the World Trade Organization.
They called on the US government to open new talks over bilateral air agreements to address what they said are violations of those pacts, giving the Gulf carriers unfair competitive advantage.
It also reiterated earlier claims that the three US carriers had received US government subsidies worth USD 70 billion in the past 15 years.
The Abu Dhabi government has invested USD 14.3 billion in Etihad Airways since its establishment in 2003, of which USD 9.1 billion was provided in equity funding and USD 5.2 billion in shareholder loans, it said.
"These commitments were made on the basis that the airline would operate commercially, deliver a long-term return on investment, repay shareholder loans and achieve sustainable profitability," Etihad said.
Around USD 5 billion of the airline's borrowings have been repaid, including USD 800 million in 2014, it said.